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Experimentals won't require TSO'd ADS-B equipment

digidocs

Well Known Member
This could be interesting:

from http://www.gpo.gov/fdsys/pkg/FR-2015-02-09/html/2015-02579.htm

FAA said:
Background

On May 28, 2010, the FAA published a final rule entitled,
``Automatic Dependent Surveillance--Broadcast Out Performance
Requirements To Support Air Traffic Control Service'' (75 FR 30160).
In that final rule, the FAA established Sec. 91.225, which
provides the ADS-B equipment requirements necessary to operate in
certain classes of airspace effective January 1, 2020. Under paragraph
(a)(1) of that section and in order to operate an aircraft in Class A
airspace, an aircraft must have installed equipment that ``meets the
requirements of TSO-C166b.'' Under paragraph (b)(1) of that section, in
order to operate an aircraft below 18,000 feet MSL and in identified
airspace described subsequently in Sec. 91.225, an aircraft must be
equipped with equipment that ``meets the requirements of TSO-C166b; or
TSO-C154c . . .''. In reviewing these paragraphs, the FAA notes that
the regulatory text implies that the equipment must meet all the
requirements of the referenced TSOs. As the ADS-B Out rule is a
performance-based rule, it was not the FAA's intent to arguably limit
operators to only install equipment marked with a TSO in accordance
with 14 CFR part 21, subpart O. The FAA's intent was to permit
equipment that meets the performance requirements set forth in the
referenced TSOs.
Evidence of that intent is found in the Notice of
Proposed Rulemaking (NPRM) for this rule. In the NPRM, the FAA proposed
in Sec. 91.225(a)(1) and (c)(1) that the equipment installed ``Meets
the performance requirements in TSO-C-166a'' (72 FR 56947, 56971). The
inadvertent removal of the word ``performance'' in the paragraphs
implementing these provisions in the final rule was in error and
resulted in confusion as to whether the regulation permits other than
equipment marked with a TSO, provided that equipment met the specified
performance requirements.

(emphasis mine)

By my reading, this is not limited to Experimental/LSA...
 
The wording change is independent of whether or not the aircraft is certified. Seems like this would help pave the way for non-installed, non-TSOd ADS-B Out equipment that would satisfy the 2020 mandate.

I think the same case could be made for the GPS providing information to the ADS-B transmitter, since the referenced TSO and FAR only specify performance requirements for the GPS. Maybe the FAA will have to weigh in on how their new words apply here.

Dave
 
don't get excited

This "change" just brings the adsb rules into the same status as other rules. You are not required to use a transponder or an ifr gps which is "TSO'd", that is, the manufacturer has issued a statement that the box meets TSO standards. You do have to use a box which meets those standards(or is substantially equivalent). The subtle difference is in who is saying it meets the specs. For most of these, though, the TSOs are so complex that it is not practical or possible for anyone other than the manufacturer to make the determination.
 
So how does one demonstrate that the equipment "meets the performance requirements" of the relevent TSO, without going through TSO or STC?
 
So how does one demonstrate that the equipment "meets the performance requirements" of the relevent TSO, without going through TSO or STC?

exactly. This is just verbage from their legal dapartment. It's in the same catagory as "owner produced parts" for normally certified aircraft. Legal, as long as you can show it's equivalent to the original. But if Cessna won't release the specs on the original (and they won't) then it's hard to show it's equivalent!
 
I think there is a (good) difference between meeting the TSO and being TSO'd.

I have a copy of the TSO/RTCA doc. for 978MHz UAT devices. It would be much easier to design/test a device to meet all of the requirements than it would to prove to the FAA that it does. It's much like the intent of LSA, you have to play by the rules but you don't have to prove it to the FAA unless asked to do so.

David
 
So how does one demonstrate that the equipment "meets the performance requirements" of the relevent TSO, without going through TSO or STC?

The same way we are now using non-TSO altitude encoders to drive a Mode-C transponder.

The required transponder tests - updated for the ADSB requirements - may be enough. Park your plane over an "X" outside the avionics shop and let them check that the position and altitude reported by your Mode-S transponder is correct, and then check the other bits...
 
I have read the ADS-B out standards and I find them incredibly complex and difficult to test (meaning way more challenging than proving an encoder works). I doubt a builder would be up to the task of confirming performance requirements. If equipment comes out that would allow an instrument tech to test ADS-B systems, it would be GREAT. The floodgates could open!

Think back to the recent thread giving ADS-B feedback from the FAA. It is the first time I saw any performance feedback and some of it was questionable based on a lengthy discussion with Bill at Navworks on some of the measurements since the ground stations can affect the measurements.
 
To Dynon, it's a clarification of what was always the way we operated. The old language was:

meets the requirements of TSO-C166b; or TSO-C154c

New language:

meets the performance requirements of TSO-C166b; or TSO-C154c

It's pretty easy to read in the first one that you didn't need to actually get the TSO, you just needed to meet it. It's nice they made this even more clear, but Dynon has not been holding out for this change to sell something.

The TSO for ADS-B and the GPS is extremely complex. In this case, the TSO paperwork is not the issue. It's the design the TSO requires and the tests you need to run in order to show you meet the TSO. Once you do all that work, why not file for the TSO?

Hence the reason Dynon sells a fully TSO'd transponder with ADS-B Out. There's no particular savings if you need to demonstrate compliance with so many technical details.

Statically testing a GPS on the ramp does not prove it is TSO'd. One of the difficult things a device that meets the TSO needs to do is provide an accurate solution even when satellites are mis-behaving (and prove you do so). There's no affordable way for a shop to to test this on the ground, and your non-TSO'd GPS will fail it anyway. Then you need a "System Design Assurance" of 1x10-5, which you can't demonstrate with a simple single test, you have to know how the system (read: software) was designed, documented, coded, complied, etc.

So unfortunately, while this at least shows the FAA is open to making the rules easier to interpret, it doesn't open up any new routes for experimental aircraft to install less expensive equipment. Dynon will keep working hard to see if we can get some other changes through to provide more solutions for experimentals.

--Ian Jordan
Dynon Avionics
 
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One advantage of the system seems to be that it tests itself in the network. When I first started flying my Dynon ADSB system there was bug in how my G430w communicated with the Dynon system resulting in an error.
I got a very non threatening call from some obscure FAA desk who not only described the problem to me but told me exactly what patch file I needed to download to fix it.
 
i hope they do, i enjoy seeing ALL of the traffic around me, especially the experimental which can be the most interesting behaving ones
 
i hope they do, i enjoy seeing ALL of the traffic around me, especially the experimental which can be the most interesting behaving ones

That's just the point, you will never see all of the traffic around you. Not today and not after 2020. Those no electrics Cubs, Tcrafts, etc. do not have transponders or ADS-B.

The ADS-B rule is another reason my next homebuilt will not have an engine driven electrical system, transponder, or ADS-B.
 
That's just the point, you will never see all of the traffic around you. Not today and not after 2020. Those no electrics Cubs, Tcrafts, etc. do not have transponders or ADS-B.

The ADS-B rule is another reason my next homebuilt will not have an engine driven electrical system, transponder, or ADS-B.

Just like gun laws, ADS-B won't apply to the "out-laws" that (for whatever reason) don't want to comply.
 
Not wanting to be seen by those around you baffles me, I don't get the outlaw mentality

And don't even put on a tinfoil hat and start barking user fees and taxes
 
Just like gun laws, ADS-B won't apply to the "out-laws" that (for whatever reason) don't want to comply.

Not an "out-law", just following the law.

My '41 T-craft had a wind driven generator mounted between the gear legs and didn't require a transponder. Thus, if I build a rag and tube fun flier and install the same type of electrical system that is not driven by the engine, there is no requirement to install either a transponder or ADS-B.

Remember, the ADS-B regs do not require airplanes without electrical systems to install one so there will always be Cubs, Champs, etc. flying round underneath controlled airspace and your ADS-B will never pick them up. The good news is those airplanes will be VFR where "See and Avoid" will still be the rule so you will have to still look out the windscreen and not at your ADS-B display.
 
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Bill,
Even with an electrical system of a 787, you don't need a transponder or ADS-B.

Transponder and ADS-B are about WHERE you want to fly. Not having an electrical system and not installing an ADS-B OUT barely increases the areas you can fly over an aircraft with electrical and not transponder installed. Stay out of Class-B/Class-C and below 10K feet and it doesn't matter what kind of generator you have. If all you want to do is go into a Mode C veil (but not Class B or C) then I guess there is a slight advantage.

You are correct that you can never rely on ANY traffic system to not see all planes, but that doesn't have anything to do with planes without electrical systems.
 
The same way we are now using non-TSO altitude encoders to drive a Mode-C transponder.

The required transponder tests - updated for the ADSB requirements - may be enough. Park your plane over an "X" outside the avionics shop and let them check that the position and altitude reported by your Mode-S transponder is correct, and then check the other bits...

I wish it was that simple. There is a lot more to the ADS-B TSO performance requirements for both the transmitter and the GPS position source than simple GPS position and altitude data. And the real problem is that the transmitter manufacturer has one piece of the problem and the GPS source manufacturer the other and someone has to prove that they actually talk to each other and meet the ADS-B out requirements as a system. This is where a unit with both has the advantage, one manufacturer who has all the data.
 
For VFR flying, why would I be required to own an IFR spec'ed GPS source? Just how far off can a GPS location be? Miles? Feet? Inches?

Does this mean that we can't fly when they NOTAM the airspace in certain areas for GPS "testing"? God forbid our reported location is incorrect!

It's called see and avoid! It might make sense for IFR and operations above 18,000', but not for us VFR flyers.
 
....If all you want to do is go into a Mode C veil (but not Class B or C) then I guess there is a slight advantage.

You are correct that you can never rely on ANY traffic system to not see all planes, but that doesn't have anything to do with planes without electrical systems.

That happens to be where most of the GA airports are located around major metropolitan areas. So gaining access inside a Mode C vail, under controlled airspace is more than a "slight advantage".

For example, inside the Charlotte mode C veil there are over 15 airports, not counting CLT, that house a variety of airplanes from Cubs to Jets. With the ADS-B rule the Cubs will be able to fly but some guy with an old Cessna 150 can't, unless he dumps a lot of cash into an ADS-B unit while the Cub owner can continue to fly around under the Bravo all he/she wants without adding a thing to the Cub.

You are correct that not all traffic systems are perfect but my comment was directed towards the idea that ALL planes will show up on ADS-B, when a number of them never will.

This rule is a mess!
 
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Note that 91.225 says nothing about an engine driven electrical system, so you can't have a wind driven turbine. You must have NO electricity on board.

(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--
 
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* * *

The TSO for ADS-B and the GPS is extremely complex. In this case, the TSO paperwork is not the issue. It's the design the TSO requires and the tests you need to run in order to show you meet the TSO. Once you do all that work, why not file for the TSO?

... There's no particular savings if you need to demonstrate compliance with so many technical details.

Statically testing a GPS on the ramp does not prove it is TSO'd. ... There's no affordable way for a shop to to test this on the ground ....

So unfortunately, while this at least shows the FAA is open to making the rules easier to interpret, it doesn't open up any new routes for experimental aircraft to install less expensive equipment. Dynon will keep working hard to see if we can get some other changes through to provide more solutions for experimentals.

--Ian Jordan
Dynon Avionics

It's good to hear from a leading equipment manufacturer on this issue, and your explanation is understandable, but accepting that to be the case, then it would seem there is no solution to the problem, except perhaps getting the FAA to reduce the performance standards set forth in the ADS-B regulations.

Is that what you have in mind when you say Dynon will keep working to see if we can get some changes to provide solutions for experimentals?

I think we need to know what regulatory change we should be working for to solve this cost problem.

Up to this point, many have believed the fundamental problem is that the ADS-B regs require certified and/or TSO'd equipment to be installed, and if we could just get rid of that requirement, and instead be allowed to use so-called "portable solutions," our problems would be solved. Your post indicates otherwise, because even "portable solutions" would still have to meet the complex performance standards and have a way of proving it.

So the question becomes, what then is the solution? It seems unlikely to me that the FAA would reduce the ADS-B performance standards, but then again I'm not an expert regarding the technical details.

The EAA article on this development quotes Doug Macnair, EAA Vice President of Regulatory Affairs, as saying, "This technical correction is a good first step, but there is much more work to do." http://www.eaa.org/en/eaa/eaa-news-...le-correction-opens-door-for-lower-cost-ads-b

Well great, but I am going to contact EAA to find out what "more work" they have in mind. The Experimental/GA community needs to know what type of reform we can work for as a solution in order to be able to get behind that reform.

EAA and AOPA are telling us they are urging FAA to permit a low cost solution to ADS-B compliance. That’s great, because that’s what we want them to do, but I can’t tell if they have a solution in mind and, if so, is there some reason they are not yet sharing it with us? Inquiring minds want to know. Or are they still scratching their heads as to what it should be?
 
It's good to hear from a leading equipment manufacturer on this issue, and your explanation is understandable, but accepting that to be the case, then it would seem there is no solution to the problem, except perhaps getting the FAA to reduce the performance standards set forth in the ADS-B regulations.

Is that what you have in mind when you say Dynon will keep working to see if we can get some changes to provide solutions for experimentals?

I think we need to know what regulatory change we should be working for to solve this cost problem.

Up to this point, many have believed the fundamental problem is that the ADS-B regs require certified and/or TSO'd equipment to be installed, and if we could just get rid of that requirement, and instead be allowed to use so-called "portable solutions," our problems would be solved. Your post indicates otherwise, because even "portable solutions" would still have to meet the complex performance standards and have a way of proving it.

So the question becomes, what then is the solution? It seems unlikely to me that the FAA would reduce the ADS-B performance standards, but then again I'm not an expert regarding the technical details.

The EAA article on this development quotes Doug Macnair, EAA Vice President of Regulatory Affairs, as saying, "This technical correction is a good first step, but there is much more work to do." http://www.eaa.org/en/eaa/eaa-news-...le-correction-opens-door-for-lower-cost-ads-b

Well great, but I am going to contact EAA to find out what "more work" they have in mind. The Experimental/GA community needs to know what type of reform we can work for as a solution in order to be able to get behind that reform.

EAA and AOPA are telling us they are urging FAA to permit a low cost solution to ADS-B compliance. That?s great, because that?s what we want them to do, but I can?t tell if they have a solution in mind and, if so, is there some reason they are not yet sharing it with us? Inquiring minds want to know. Or are they still scratching their heads as to what it should be?

I see a couple of possible solutions:

1. Reduce the performance standards and/or allow non-certified/TSO'ed/TSO-equivalent equipment in aircraft that are solely operated VFR. I really don't see why the GPS and transponder for an aircraft operating VFR need to meet the same reliability, integrity, and accuracy standards as the GPS an airliner uses to fly an approach in IMC into Atlanta or Chicago or NYC. That is, quite simply, overkill.

2. Reduce the performance standards and/or allow the use of non-certified/TSO'ed/TSO-equivalent equipment in single-engine aircraft under 6000lb (even those operating night/IFR), with the stipulation that ATC may deny IFR clearance or clearance into Class B/C airspace if they have reason to believe the equipment is not reporting accurately or would present a hazard at that time.

3. Remove the requirement for ADS-B within the Mode C veil.


I don't think we'll ever see portable units being allowed. But if we could get rid of some of the ridiculous performance requirements and the expensive paperwork and testing required to meet them, I think we can bring the cost down into the affordable range.

A couple points for any FAA types reading this:

Remember, we need to balance the chance of failure against the possible consequences. We need that level of integrity for airliners or business jets conducting parallel approaches in IMC, buti If the ADS-B system of a C-150 fails or is reporting even half a mile off while VFR in the Mode C veil but outside Class B, what's the real risk? That's routine with current Mode C and radar.

The cost to equip with ADS-B doesn't scale linearly or directly with the airplane or the real operational need. Equipping a transport-category aircraft with ADS-B out is expensive in absolute terms--it costs as much or more than my house--but those costs are relatively small in proportion to the purchase price and operating costs. Equipping a light aircraft costs much less in absolute terms, but as a fraction of aircraft hull value and operating costs, it is much greater. For many owners, the cost for a 2020-compliant system can exceed their entire annual flying budget (including hangar/parking, fuel, maintenance, annuals, etc). In short, the performance and certification requirements for 2020-compliant ADS-B systems impose the largest burden on those who have the least actual need for them.
 
Adam Smith

Says the silent hand of competition will always be there. You can bet your bottom dollar that all the avionics boys are delving in to this with all hands on deck. They are doing their research and you will see low cost simple hardware to make this happen by whenever this really does go into effect. I'm not going to get wrapped around the axle just yet although I AM paying attention. Resistance is futile.....
Best,
Brian
 
Just like gun laws, ADS-B won't apply to the "out-laws" that (for whatever reason) don't want to comply.

Sorry, folks. I didn't mean to imply that legitimate planes without electrical systems were outlaws. My understanding is that ADS-B will replace radar and when that happens, true "outlaws" carrying illegal contraband or people across borders, etc. will go undetected.
 
Sorry, folks. I didn't mean to imply that legitimate planes without electrical systems were outlaws. My understanding is that ADS-B will replace radar and when that happens, true "outlaws" carrying illegal contraband or people across borders, etc. will go undetected.

Highly unlikely ADS-B will replace military radar in the border ADIZ areas.
 
I wish it was that simple. There is a lot more to the ADS-B TSO performance requirements for both the transmitter and the GPS position source than simple GPS position and altitude data. And the real problem is that the transmitter manufacturer has one piece of the problem and the GPS source manufacturer the other and someone has to prove that they actually talk to each other and meet the ADS-B out requirements as a system. This is where a unit with both has the advantage, one manufacturer who has all the data.

Does that say that the easiest (and probably cheapest) solution may be an all-in-one box that is a GPS/Altitude Encoder/Mode S transponder? One with a big red "error light" visible to the pilot to announce a failure.

If that's the case, the solution may come from a drone avionics supplier. :)

I presume the ADSB-in boxes are not really connected to these requirements since they are for pilot displays only.
 
while the Cub owner can continue to fly around under the Bravo all he/she wants without adding a thing to the Cub.

This is not the case now, so I doubt this will be the case later.

Currently a non-electric aircraft can fly under Class B with-in the Mode-C veil, but with restrictions.
They must set it up in advance with ATC and the approval is usually for a specific route to get from an airport using the shortest reasonable path out of the 30 mile radius area or the reverse if needing to come in. I'm sure there are exceptions to this, if someone needs to fly to another airport within the veil, etc.... the point is, even now, non equiped aircraft don't have the freedom to fly where ever they want, when ever they want, beneath the Class B.
 
Does that say that the easiest (and probably cheapest) solution may be an all-in-one box that is a GPS/Altitude Encoder/Mode S transponder? One with a big red "error light" visible to the pilot to announce a failure.

If that's the case, the solution may come from a drone avionics supplier. :)

Yeah, I guess it would actually be the cheapest solution if someone would make one. The closest I've seen is the UAT/GPS combo that several companies now have.
 
This is not the case now, so I doubt this will be the case later.

Currently a non-electric aircraft can fly under Class B with-in the Mode-C veil, but with restrictions.
They must set it up in advance with ATC and the approval is usually for a specific route to get from an airport using the shortest reasonable path out of the 30 mile radius area or the reverse if needing to come in. I'm sure there are exceptions to this, if someone needs to fly to another airport within the veil, etc.... the point is, even now, non equiped aircraft don't have the freedom to fly where ever they want, when ever they want, beneath the Class B.

That's not how I believe things operate now. If you have no electrical system (ie certified without one) there are no limitations to operating inside a Mode C veil without a transponder as long as you stay clear of any Class B/C airspace.
 
That's not how I believe things operate now. If you have no electrical system (ie certified without one) there are no limitations to operating inside a Mode C veil without a transponder as long as you stay clear of any Class B/C airspace.

Your right.

I have been involved in getting blanket wavers during fly-ins to allow out of the area aircraft to enter the 30 mile veil without prior ATC permission. It looks like that was for aircraft certified with electrical systems but not Mode C equipped.

I stand corrected.
 
Would that be like this system, but with a pilot input for transponder code?

http://www.nextgenuastransponders.com/ads-b-one/

I presume the ADSB-In box is separate and not confined by the same TSO requirements.
Somewhat similar. If you have a UAT you either need a system that can pick up the code from the transponder (garmin does by serial data, others do by listening to the transponder output) or a separate ADS-B out control in the panel for code entry.

The only regulatory requirement is for out. There is discussion about peformance expectations for in, but right now strictly optional.
 
Question: If one was to install an ADS-B system (portable, installed, or whatever) and then get a "clean" report from that FAA email address you can send your N-number to, does the passing result imply that the system is performing to the TSO spec? That system appears to evaluate a large number of data points to ensure they're reliably and properly received, and to validate the actual data based on some pretty strict criteria. Portable ADS-B Out devices that I have seen include certain configuration settings (for now at least) that prevent a clean report, but I wonder if there might there be a path toward evaluating actual performance against the TSO spec using that FAA-provided service? Or is there more to it?
 
Question: If one was to install an ADS-B system (portable, installed, or whatever) and then get a "clean" report from that FAA email address you can send your N-number to, does the passing result imply that the system is performing to the TSO spec? That system appears to evaluate a large number of data points to ensure they're reliably and properly received, and to validate the actual data based on some pretty strict criteria. Portable ADS-B Out devices that I have seen include certain configuration settings (for now at least) that prevent a clean report, but I wonder if there might there be a path toward evaluating actual performance against the TSO spec using that FAA-provided service? Or is there more to it?

The short answer is no. There and many more performance items than measured by the FAA report.
 
Note that 91.225 says nothing about an engine driven electrical system, so you can't have a wind driven turbine. You must have NO electricity on board.

See §91.215 ATC transponder and altitude reporting equipment and use.

From the FAA's ADS-B FAQ:

FAA ADS-B FAQ said:
Will aircraft be able to fly in a non-transponder area without ADS-B?

For the most part, the ADS-B Out mandate covers the same airspace where transponders are required. However, to be sure of the regulatory requirements it is best to check 14 CFR § 91.225 for ADS-B-designated airspace and 14 CFR § 91.215 for transponder-designated airspace.

Also, I checked with AOPA and they confirmed the above. For aircraft that were not certified when manufactured and have never been subsequently certified with an electrical system, there will be no change for them. They may continue to operate within the Mode C veil, as long as they stay clear of controlled airspace.
 
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Bill,
I was mentioning that 91.225 (ADS-B) differs from 91.215 (transponder).

91.215 uses "engine-driven electrical system" and 91.225 just uses "electrical system."

Just pointing out that when you said:
My '41 T-craft had a wind driven generator mounted between the gear legs and didn't require a transponder. Thus, if I build a rag and tube fun flier and install the same type of electrical system that is not driven by the engine, there is no requirement to install either a transponder or ADS-B.

This isn't true for ADS-B. You can't get around the ADS-B requirement by having a generator that isn't spun by the engine. You must have no electrical system at all to fly under the Mode C veil and not have ADS-B.
 
I can see a lot of grounded RVs as the date approaches while on workbenches across America, old instrument panels are discarded and all new ones are still being assembled.

I know a lot of RVers -- I guess all of them, from what i can tell -- just write a check and have everything done for them. But this deadline is a lot closer than I think people think for those of us who are going to have to rebuild entire panels because the requirement isn't just for ADS-B.

and that assumes working people can afford it, which is problematic.

Similarly, I wonder what this mandate will do to the value of RVs as the date gets closer if they aren't properly equipped?
 
I'm a pessimist

I've read a lot of posts here with "what if's", but I'm afraid in the end we're all just going to have to pony up money, or avoid over 10,000' and anywhere near Class B, C airspace. Here's why:

The FAA technical specification guys were allowed to go crazy. Consequently, to show compliance with the TSO requires many man-years of engineering and management time. In other words, there's a lot of up-front costs. These costs are built into the price.

The companies that were/are first to market are already paying down those R&D/up front costs. Some may have already done so. So if a new company comes along, the established guys can afford to lower their prices enough so that the new company can never pay off its costs. The new companies know that, so they don't even try.

The FAA won't back down on the specifications. If they did, the already-established in the market companies would cry foul, and they'd have a case.

As an example, we've had TSO compliant ifr gps units for some time now. Has anyone seen the prices going down?

The only glimmer of hope I see in this slight rules change is that some very clever company might find a way to show that their box meets all the performance specifications without having to meet all the details of the TSO, and that this might be a big-cost saver. But given the details of the TSO specs, I doubt it very much.
 
...This isn't true for ADS-B. You can't get around the ADS-B requirement by having a generator that isn't spun by the engine. You must have no electrical system at all to fly under the Mode C veil and not have ADS-B.

I think the way the FAA looks at is that "engine-driven electrical" system is the key. Even with the wind generator, I would be exempt.

That said, I am checking and will report back.
 
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I wont be able to afford the TSO version of anything related to ADS-B and still be able to fly as regularly as I do.
So hopefully there will be some adhoc, glaresheild mountable antenna, iWhatever app driven, USB powered doodad that will satisfy the feds and keep me flying with minimal expenditure.
 
Something's gotta give, FAA says 2020 mandate is firm, Inspector General says no

AOPA’s Position (a pull from AOPA)

For nearly 20 years AOPA has supported the transition from ground-based infrastructure to satellite based systems. AOPA generally supports the ADS-B concept and recognizes the importance of near-universal participation. Aircraft operators who can identify clear benefits to their operations and can afford to do so are encouraged to equip ahead of the ADS-B Out mandate.

However, it is difficult to identify adequate benefits in the ADS-B implementation strategy for some operators, particularly the owners of low-value piston-powered aircraft. AOPA expects many of its members to delay equipage as long as possible and anticipates some will be forced to ground their aircraft in 2020 unless a lower cost solution can be found. As noted in comments to the FAA, AOPA continues to have a number of concerns with FAA’s implementation strategy to include:

Affordability. AOPA has recommended several technical changes that would reduce the price of ADS-B systems. AOPA has also called on the FAA to permit pilots to use hand-held ADS-B receivers that can obtain free traffic, weather, and airspace status content from the ADS-B infrastructure.
Collision risk. The FAA is implementing ADS-B on two independent, non-compatible frequencies. Unless general aviation pilots equip aircraft in such a way that they receive the ADS-B transmissions on both frequencies, they will likely see only one-half of the ADS-B equipped fleet. The costs and availability of dual-frequency ADS-B receivers is not known. The FAA could address this concern in two ways: 1) either provide a re-broadcast service at all general aviation airports or 2) require all aircraft to transmit on the same frequency.
Mandate not necessary. AOPA recommended that the FAA exclude low-altitude operators from the mandate because the financial benefits all stem from operations in high altitude airspace, over the Gulf of Mexico, or when operating to and from the largest airline airports. An independent FAA-sanctioned rulemaking committee confirmed the AOPA recommendation would achieve most of the benefits without the widespread mandate on general aviation.
Transponder removal. AOPA recommended that because the FAA plans to transition from radar and transponders to ADS-B, that general aviation aircraft should be allowed to remove their transponders. However, the FAA has rejected that proposal, primarily because they have not adapted Traffic Collision Avoidance System (TCAS) to support ADS-B.
ADS-B infrastructure. The FAA has installed the ADS-B infrastructure to provide the same coverage as radar. Except for overwater, deep in the Gulf of Mexico, no new airspace or airports are expected to receive surveillance as a result of the ADS-B infrastructure installation.

Status / Next Steps for ADS-B

In September 2014, the Department of Transportation’s Inspector General released a report identifying numerous problems with the ADS-B implementation process, including many that were raised previously by AOPA. The problems included delays, cost overrruns, the high cost to equip, lack of benefits, issues with data integrity, coverage gaps, and more.

On Oct. 28, 2014, AOPA President Mark Baker sent a letter to the FAA administrator urging the agency to address the negative economic impact of the mandate on general aviation, the logistical challenges of meeting the mandate, the potential to lower the cost of compliance through the use of alternative equipment standards, and the findings of the Inspector General’s report.

The letter noted that the minimum investment of $5,000 to $6,000 to install ADS-B-Out equipment is “far too high” for many GA operators, especially given that the general aviation fleet includes at least 81,564 certified, piston-powered, fixed-wing aircraft that are valued at $40,000 or less, and that GA owners have no way to recoup their costs.

Also in October 2014, AOPA participated in an FAA-sponsored Call to Action to identify the barriers to meeting the ADS-B Out mandate. AOPA is now working with the FAA, avionics manufacturers, and industry experts to develop solutions to overcome those barriers as part of the Equip 2020 group.

AOPA is pleased that the FAA is prepared to address the barriers to compliance with the mandate and confident that the cost issue can be effectively addressed so that all segments of the general aviation community can participate in ADS-B Out and the FAA can meet its goal of modernizing the nation’s air traffic system.
 
Basically, AOPA got what it asked for and now doesn't like what it got.

The organization's leaders missed the boat on this a decade ago and no amount of repositioning their official stance can remove partial responsibility from AOPA's doorstep.
 
Yeah, it's way too late for AOPA to expect these changes to happen now.

Their position reminds me of so many advocacy groups. Their message is for the "base", to keep the faithful, faithful. But their actual position is something different. And that's usually a good thing. Clinging to the extreme position doesn't accomplish anything.

What I'd like is what Mac McClellan wrote in Sport Aviation. Loosen the GPS requirement if you don't go into Class B and C, or won't do IFR, where the airliners go. That would allow most of us to use a much cheaper GPS for almost all the flying we want to do.

AOPA has also called on the FAA to permit pilots to use hand-held ADS-B receivers that can obtain free traffic, weather, and airspace status content from the ADS-B infrastructure.
That's done now. Did AOPA mean hand-held receivers in Class B airspace? Or hand-held transmitters? AOPA needs to reword this to make it clear what they want.
 
To Dynon, it's a clarification of what was always the way we operated. The old language was:



New language:



It's pretty easy to read in the first one that you didn't need to actually get the TSO, you just needed to meet it. It's nice they made this even more clear, but Dynon has not been holding out for this change to sell something.

The TSO for ADS-B and the GPS is extremely complex. In this case, the TSO paperwork is not the issue. It's the design the TSO requires and the tests you need to run in order to show you meet the TSO. Once you do all that work, why not file for the TSO?

Hence the reason Dynon sells a fully TSO'd transponder with ADS-B Out. There's no particular savings if you need to demonstrate compliance with so many technical details.

Statically testing a GPS on the ramp does not prove it is TSO'd. One of the difficult things a device that meets the TSO needs to do is provide an accurate solution even when satellites are mis-behaving (and prove you do so). There's no affordable way for a shop to to test this on the ground, and your non-TSO'd GPS will fail it anyway. Then you need a "System Design Assurance" of 1x10-5, which you can't demonstrate with a simple single test, you have to know how the system (read: software) was designed, documented, coded, complied, etc.

So unfortunately, while this at least shows the FAA is open to making the rules easier to interpret, it doesn't open up any new routes for experimental aircraft to install less expensive equipment. Dynon will keep working hard to see if we can get some other changes through to provide more solutions for experimentals.

--Ian Jordan
Dynon Avionics

Thanks, Ian.
This makes my brain hurt, so can you please help put this into perspective? For my -7A's avionics, I've installed Skyview with integrated transponder, GPS, and your ADS-B. Given this new info, what am I still missing?
 
Scroll,
For someone in your situation, which is a person with a Dynon transponder installed, what you need is a GPS on board that is compliant with the rules. This unfortunately is not the one integrated into SkyView, due to the requirement that it "meet the TSO" which is a very complex thing to demonstrate.

So, by 2020, you will need a new GPS, but that's it. Dynon's recommendation for someone in your situation is to wait. You still have years to comply, and industry has years to make a set of solutions you can choose from. As more affordable solutions come up, Dynon will be there to support them and give guidance on what you need to be sure you are legal.

--Ian
 
Scroll,
So, by 2020, you will need a new GPS, but that's it.
--Ian

My understanding is a devilish detail remains: A TSO'd txpndr + TSO'd, IFR-legal GPS is still not a legal ADS-B system. The whole system, including the wires, where the antenna is, in a one-of-a-kind EAB plane, has to meet the TSO performance requirements.

Before the FAA's clarification, the ADS-B regs seemingly required a (supplemental) type cert to prove full compliance with the ADS-B 2020 mandate. Since EABs by definition have no type certs, no Bravo, Charlie, or Mode C veil flying allowed.

Now, an (S)TC is not required, just a demonstration your unique, one-of-a-kind EAB aircraft's ADS-B system meets TSO's performance requirements. Apparently, that's still such a complex, expensive thing to accomplish, few EAB owners could do it.

I think this also means you can buy the exact same parts for a certified plane's ADS-B system (even an all-in-one txpndr-GPS-encoder-antenna box as other posters have suggested), have them installed in your EAB by shop with all the qualifications to work on certified ships, and pay the certified prices for the whole shebang...and it wouldn't be recognized by the FAA as a mandate-meeting ADS-B set-up, unless it was tested as a system according to the complex, expensive methods that earned a certified plane its (S)TC.

If I'm not wrong, the Dynon txpndr can continue to be hooked up to Dynon's GPS (or any other GPS device for that matter) after 2020. But the the bits and bytes in the extended squitting will declare "I am not a 2020-compliant ADS-B out broadcaster!!!". You'll still be able to wake up ground stations and get receive ADS-B in traffic, etc. But stray 1 yard inside a Mode C veil and the FAA will probably tell the NTSB's administrative law judge that by gum, they're 100% positive the GPS position was accurate, so the pilot certificate action is justified. <Insert Law & Order Cha-Chunk Sound here>
 
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