The FAA change was simply to bring ADSB requirements in line with other "certified" stuff, like transponders and ifr GPS boxes. You do not need to use a TSO'd transponder (or ifr gps, or, now, ADSB-out). But the owner/operator must be able to show that these boxes meet the TSO performance standards. This is a whole lot more than sensitivity numbers. There's an engineering analysis that predicts an error of less than one in 10 million; How is the typical owner/operator going to show that this box meets that standard, unless the manufacturer says it does (by way of getting a TSO)? As several equipment manufacturers have commented here, it is not the paperwork that is expensive; it's the actual engineering time to do the tests and analysis. This new wording still requires that the gps meet all 91.227 requirements. It's not enough to send out "SIL=3"; you have to be able to back that up, that that requirement is actually met. So if Navworx can release all their test data, showing compliance, then I'd say great. But until then I'm not jumping in.