peter

Tony is kind of right. TSO is not mandatory; it is just one way to show that a part is approved. There are also other ways to achieve approval of a part. For example, the EFIS displays in most (perhaps all) Boeing aircraft are not TSO’d, rather they are approved under the TC process. However, the original question was about installing a non-certified EFIS in a part 23 aircraft for supplemental use, where the EFIS would be in addition to the existing instruments. In this specific case I think the FAA has been very clear. Under FAR part 21, all changes to a certified aircraft must be approved. Major changes require STC, while minor changes may be approved in a “manner acceptable to the administrator”. FAA Order 8900.1 tells FSDOs that a field approval (e.g. an FAA approved form 337) is not permitted for EFIS; an STC is required. There is a flight standards memo that says that TSO and STC are required for EFIS. There is FAA advisory circular AC23.1311-1B which states that installation of instruments that show primary flight information (attitude, altitude, airspeed) for "situational awareness" is not acceptable. Such installation must show compliance to the rules. The AC says that those systems must be certified under part 23, and the equipment should meet the minimum standards of applicable TSOs. So, in answer the original question, installation of an unapproved EFIS for supplemental use is only acceptable if an STC is obtained for that installation. A field approval is not permitted and a log book entry would not be acceptable. On the more general question of whether a part needs TSO to be installed, the answer is no. TSO is not mandatory; however, parts do need to be approved. There are various ways by which parts can be approved. TSO is one way for a part to be considered approved. Other ways include PMA (an STC process), approval under Type Certificate, field approval, standard parts, and some other methods approved under part 43 (rules for repairs) and part 145 (repair stations). In addition to the part itself being approved, an approval is needed to install the part. Installation approval may be obtained by STC, TC, amended STC or TC, major alteration or repair (form 337) and minor alteration or repair (A&P or IA sign off). Sometime a part is approved by virtue of the installation approval. When it comes to certification basis (i.e. Car3 versus FAR 23), FAR 21.101 is a rule that can require a modification to also meet the latest certification rules instead of the original certification basis. This may be the case if the original rules are not sufficient, or did not consider the type of modification being considered. For example, for EFIS systems CAR3 did not envision this type of technology and the FAA requires these system to meet more modern rules, such as rules for HIRF and lightning. An amendment to part 21 will become effective next April that further clarifies requirements for replacement and modification parts. This forthcoming rule change says that any replacement or modification article that a person knows, or should know, is reasonably likely to be installed on a type- certificated product, must be produced under TC, an FAA production approval (such as TSO or PMA), be a standard part (such as a MS bolt), or be a defined commercial part (i.e. identified by a TC or STC holder in an ICA), be an owner produced part (owner produced parts still need to have a design approval), or be manufactured by a certificate holder with an approved QA system. Guys, I don’t make these rules, and often wish they were different. However, it is my business to know the rules and work within them. When it comes to the products my company produces, we must adhere to the rules, guidance and policy published by the FAA or we will leave our customers in a tough spot. When it comes to your personal aircraft you will have to make your own decisions about what to do.

Quote: tony This is a great conversation over a beer. Peter you are right, but lets not forget 25.1309 which says. There shall be no single element in the design that,if it fails, an maifest itself as a catasptophic event. Isn't the DO-178B software thats in your displays an element? Perhaps we should just keep those airspeed, altitide and attitiude indicators just to mitigate the hazard?

Quote: Vref Would this mean also the output will have a Heading synchro signal that can be used for e.g a WX11 stormscope whch uses heading information currently coming from the bootstrap of the KI 525A HSI..?..

Quote: Vref Ok Peter thank you for the clarifications, but a lot of King A/P's around no..?. this adds up to 15000 $ if you want to get rid of the KI256 and not 20K$ then (comment accepted)...Can I use my synchro ADF signals through the Aspen unit..?... Mooney Pilots are critical....sorry for that.......

Quote: N223MM What if the secondary EFIS were out of the pilot's direct line of site? I ask because this looks like it is in a certified aircraft. Or, maybe this was done before the memo that was mentioned came out?

Quote: Vref What never seems to be discussed with Aspen units or even Garmin that for interfacing an A/P you need additional hardware adding up to the expense...(2500 $ for EA100 I believe for the unit only)..so all in all it looks like more closer to 20K$ for a full capable A/P integrated glass panel the cheapest version...

Quote: 1964-M20E My question regarding TSO, PMA certified vs. non certified is this. Is it safe or not? If it is safe to be placed in an experimental type then why not in a certified type? The experimental if flying around just the same as the certified type sometimes higher and faster than most certified types.

Quote: Piloto Question: Does the emergency battery duration limits how far I can fly from suitable landing site? Like if I am a charter flying to Bermuda or the Azores at night what would be the procedure after the battery runs down and I have no stand-by instruments. As you surely knows battery charge duration is much less after a few years of use.

Quote: tony When you do the Functional Hazard Assessment (FHA) you’ll soon find out that the electrical system is a single point failure and can never support catastrophic events.

Quote: tony Furthermore I haven’t seen a single STC for an EFIS device that did not include the vacuum supported functions installed with the old instruments in the panel as well.

Quote: Piloto Would you need to have dual alternator for the above? Coming from Santa Maria (LPAZ) to St John's (CYYT) I lost the alternator in IFR conditions at 400nm from LPAZ. I had to shutdown all the electrical systems to save battery knowing that I would need to make an ILS approach to minimums at CYYT. Luckily this plane had vacuum driven ADI and heading gyros that I was able to use for the next 7 hours of flight. I only needed to turn electrical power on once an hour for GPS position fix and HF position report. I was able to land at CYYT in IFR conditions with no event. The electrical problem turned out to be a loose belt tension bolt on the alternator. Having a long duration alternate power source is a must if you want to continue having the existing redundancy you have with vacuum gyros.

Quote: M016576

Quote: M016576 a Non-STC'ed synthetic vision PFD like the Dynon 10" Skyview costs 3k.

Quote: Tom We are talking about EFIS/instrumentation here. It is a straw man argument to attribute an increase accident rate in the experimental community to non-TSO EFIS/instrumentation. Being in the industry, you must have some statistics to substantiate your claim?

Quote: Piloto Peter I agree with you in part on the above. But keep in mind that any TSOd unit all that it has to meet for environmental conditions is the RTCA/DO160D standards. Not the MIL-SPEC for military combat environment. Although I am sure the Aspen can withstand spikes caused by lightning into the airframe I doubt it can survive a direct 20MeV strike at the tip of a lightning rod. Or the effects of an EMP caused by a near by nuclear detonation that would sterilize the pilot. I am sure the Aspen can widthstand the lightning effects in a Mooney but have my doubts in a Cirrus. But wouldn't matter because there would be no live pilot to tell about. José

Quote: Tom Given the utter lack of airplanes falling out of the sky and/or crashing into granite secondary to the GPS evolution "problem" in certified aircraft one must wonder who benefits from a rules change to outlaw the evolution. In all seriousness, a review of the accident database finds many examples of where a non-TSO EFIS costing <$2K would have likely saved lives in certified aircraft accidents. A review of the accident database at the same time does not seem to suggest a spike in experimental aircraft accidents on account of non-TSO instrumentation. The cost of GA flight continues to climb while wealth has been stagnant for decades. We simply can not continue on a path that enables ever increasing/hyper-inflated costs at the expense of excluding potential aviators from flying. And given that there is no substantial evidence to support TSO over non-TSO in many situations, there is no logical impetus to maintain such policies (unless you work in the regulation business or for a TSO manufacturer).

Quote: M016576 hmm... if all the displays were the same (lower) price, then maybe I'd agree... I can't help but feel like even the "cheap" PFD's are over priced. Obviously, I don't know how much each component costs in the PFD, etc, but I find it hard to believe that the parts to build the PFD are so much more expensive than the parts to build the MFD that they command nearly 2 thousand dollars more. Or that the Pilot PFD and the Pro PFD have a dramatic component cost difference (perhaps a software cost difference though) that justifies the nearly doubling in price. As such, I see the "double dip" as the initial upfront cost delta for either the better suited to VFR pilot PFD over the MFD.... or the price delta for an instrument rated pilot to install the more capable pro unit over the pilot PFD plus MFD (so it seems to me that for the cost of a bit of software development, Aspen is double dipping....) But, I'm on the consumer end, not the seller end: business is business. and clearly there's a market for it. Someday, maybe, this stuff will be (more) affordable for the "little guy." -JoB

Quote: tony Peter, I can’t see the FAA letter you posted, can you post the link so I can read it myself? I do believe that Geoff said in addition to. So if it is in addition to, assuming Geoff doesn’t change the cert basis, and his A&P generates a 337 that has an analysis stating that the power, weight, etc is within the capacity of the aircraft systems (therefore not effecting the airworthiness); why can't he add something that's non TSO'd ? If I want to add a non TSO’d DME to my aircraft and I promise to use it as a navigational aid and not navigate to it while flying IFR what’s wrong with that? There are a lot of people mounting Garmin 696, Aero’s, Av8or’s in their panels, are they illegal?

Quote: Geoff Thanks Peter. Is it possible/legal to install the Aspen EFD 1000 MFD as a stand alone and have it always display the backup PFD?

Quote: Geoff I was curious if it were legal to add non-TSO'd instruments to the panel of a certified airplane. I'm talking about adding a non tso'd efis IN ADDITION to the existing instruments for added situational awareness. Similar to the addition of a "panel mounted" portable GPS. Anybody ever investigated this?

Quote: FlyingAggie He also claims that because of the lower temperature most 252 engines will make TBO.

Quote: tony I have read this string a few times and I have a question for those guys that did this mod. If you have to keep the airspeed indicator, artificial horizon and altimeter (you maintaining the failure modes of the cert basis) when you install the Garmin unit, Is there a way to replace the function of the turn and bank indicator to keep the PC functioning? or do you have to keep that indicator as well? I guess I have the same question for Peter who installed the 3 aspen units.

Agreed, it is hard to argue against the NTSB recommendations to improve training requirements since this will help pilots keep pace with the changing technological landscape. Yes, there are disagreements between ASF and the NTSB on the methods used in Nall. However, Nall’s conclusions about relative accident rates between different flight profiles are not affected by this disagreement. The historical accident data for GA predicts that accidents during IFR cross country flight will have the highest fatality rates, and that accidents flying around the pattern with an instructor will have the lowest. It turns out that in the NTSB study the glass aircraft were used mainly on IFR cross country flights, and the non-glass aircraft were used mostly for local training flights. My opinion is that it would have been more meaningful for the NTSB to evaluate the fatality rate of the glass equipped aircraft on an IFR cross country flight versus non-glass equipped aircraft operated the same way, but the NTSB stopped short and did not do that analysis. The bottom line is that their observations that the glass equipped aircraft had a higher fatality rate doesn’t tell the whole story since it didn’t consider differing mission profiles among the accident aircraft.

Quote: M016576 BREAK BREAK- I wrote my Master's capstone on this very subject: Safety in General Aviation with glass cockpits. The NTSB released a study from the past 10 years on safety and fatality rates in general aviation aircraft equipped with glass vs. conventional. Turns out that while the overall mishap rates dropped in glass cockpit equipped aircraft, fatality rates went up significantly. The report is on the NTSB website (about 80 pages of information, broken down by age, aircraft type, IMC vs VMC, etc). I highly recommend checking it out. The conclusions of the report state that the FAA should consider more training or qualifications for part 91 pilots prior to using glass. -Job

Quote: allsmiles The decision to install glass or not is a classic case of needs vs wants. Do we need glass? No of course not!! The answer is an unequivocal NO. It does not add to safety more than doing what I already mentioned above.