Possible change to ads-b rule.

[N601RX]

http://www.avweb.com/avwebflash/news/FAA-Amends-ADS-B-Rule223533-1.html

Here is more. Some are interpreting that this may not be limited to experimentals.

Quote:

Originally Posted by FAA

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 ((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 ©(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.

[Hank]

There's always hope . . . C'mon, hope!!

[Hector]

That might be significant !! Opens the door for more options.

[ryoder]

If a non tso transponder is good enough for an experimental or lsa it should be good enough for my 50 year old Mooney. Separation is separation.

[mooniac15u]

How long have you guys been flying?  Experimentals have always been allowed to use non-TSOd stuff.  The price of admission to certificated planes is TSO/PMA/STC for your equipment.  You knew the rules when you bought your planes. 

[Marauder]

You knew the rules when you bought your planes.

Doesn't mean we have to like them or can't complain about them!

[aviatoreb]

How long have you guys been flying?  Experimentals have always been allowed to use non-TSOd stuff.  The price of admission to certificated planes is TSO/PMA/STC for your equipment.  You knew the rules when you bought your planes. 

 

Unless the FAA will do what they were told to do and give us that part 23 rewrite.

[Mooneymite]

How long have you guys been flying?  Experimentals have always been allowed to use non-TSOd stuff.  The price of admission to certificated planes is TSO/PMA/STC for your equipment.  You knew the rules when you bought your planes. 

 

Uh....I don't think under part 91 we are required to operate all TSO'd equipment, are we?  However I think that our transponders/encoders are required to be TSO'd, so changing that requirement will help us when equipping for ADS-B.

 

Is there a Non-TSO'd ADS-B solution available?  Is it significantly cheaper?

[mooniac15u]

Doesn't mean we have to like them or can't complain about them!

 

Kinda like the folks who knew the airport was there when they built their houses and yet still complain about all those airplanes?

[N601RX]

Uh....I don't think under part 91 we are required to operate all TSO'd equipment, are we?  However I think that our transponders/encoders are required to be TSO'd, so changing that requirement will help us when equipping for ADS-B.

 

Is there a Non-TSO'd ADS-B solution available?  Is it significantly cheaper?

http://www.navworx.com/products-PADS-B.php

[Mooneymite]

http://www.navworx.com/products-PADS-B.php

Thanks.  I didn't know about this.  $1000 with no installation cost!

 

>>>DELIVERIES TO START APPROXIMATELY MARCH 7.<<<

[midlifeflyer]

Uh....I don't think under part 91 we are required to operate all TSO'd equipment, are we?  However I think that our transponders/encoders are required to be TSO'd, so changing that requirement will help us when equipping for ADS-B.

 

Is there a Non-TSO'd ADS-B solution available?  Is it significantly cheaper?

 

It's not a Part 91 issue. It's an aircraft certification issue regarding installed equipment. If the applicable regs require that installed equipment be "approved" it needs to be TSO'd or PMA'd. So, for example, in an aircraft with a standard airworthiness certificate, our panel-mount GPS need to be TSO'd; our headsets do not.

 

I think this change is primarily applicable to the experimental and LSA markets, although I guess the question of portable ADS-B out like NavWorx is still an open one.

[wiguy]

I'm standing by for a change to the '2020 mandate'.

[N601RX]

Here is the actual reg after the change. The reg itself is not specific to experimental or certified planes, but the end of the 1st line still uses the language "has equipment installed".

 

91.225 Automatic Dependent Surveillance-Broadcast (ADS- Out equipment and use.

(a) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft in Class A airspace unless the aircraft has equipment installed that—

(1) Meets the performance requirements in TSO-C166b, Extended Squitter Automatic Dependent Surveillance-Broadcast (ADS- and Traffic Information Service-Broadcast (TIS- Equipment Operating on the Radio Frequency of 1090 Megahertz (MHz); and

(2) Meets the requirements of § 91.227.

( After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft below 18,000 feet MSL and in airspace described in paragraph (d) of this section unless the aircraft has equipment installed that—

(1) Meets the performance requirements in—

(i) TSO-C166b; or

(ii) TSO-C154c, Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS- Equipment Operating on the Frequency of 978 MHz;

(2) Meets the requirements of § 91.227.

* * * * *

[midlifeflyer]

 

Here is the actual reg after the change. The reg itself is not specific to experimental or certified planes, but the end of the 1st line still uses the language "has equipment installed".

 

91.225 Automatic Dependent Surveillance-Broadcast (ADS- Out equipment and use.

(a) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft in Class A airspace unless the aircraft has equipment installed that—

(1) Meets the performance requirements in TSO-C166b, Extended Squitter Automatic Dependent Surveillance-Broadcast (ADS- and Traffic Information Service-Broadcast (TIS- Equipment Operating on the Radio Frequency of 1090 Megahertz (MHz); and

(2) Meets the requirements of § 91.227.

( After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft below 18,000 feet MSL and in airspace described in paragraph (d) of this section unless the aircraft has equipment installed that—

(1) Meets the performance requirements in—

(i) TSO-C166b; or

(ii) TSO-C154c, Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS- Equipment Operating on the Frequency of 978 MHz;

(2) Meets the requirements of § 91.227.

* * * * *

 

 

Yeah, the amendment inserted the word "performance" before the word "requirements."

[cliffy]

Instead of speculation, I wonder how long it would take for someone to get an answer from FAA for a legal interpretation of "installed equipment" and " meets performance" as far as CAR3 and Pt 23 aircraft are concerned?

[Cruiser]

the answer is...... nothing new here people, just move on.

 

If a manufacturer has to test the equipment to the TSO standard to demonstrate "performance" they might as well get the paperwork too. The cost will not be any less, this is just FAA double talk to get past a problem in the way the original regulation was written.

[midlifeflyer]

the answer is...... nothing new here people, just move on.

 

If a manufacturer has to test the equipment to the TSO standard to demonstrate "performance" they might as well get the paperwork too. The cost will not be any less, this is just FAA double talk to get past a problem in the way the original regulation was written.

Equipment intended for the light sport and experimental markets generally costs less than those intended for the certified aircraft market. Compare the cost of, fro example, Garmin glass with equivalent features for those two markets. Same for transponders, nav/coms, etc...

 

[N601RX]

Val is a good example of a company that makes Nav receivers and radios that "Meet or Exceed the TSO" but are not TSO approved. Their products are considerably cheaper than companies who sell TSO products.

 

http://www.valavionics.com/nav-2000.html

[kortopates]

I agree with Cruiser (Tom) above. To demonstrate meeting the "performance requirements" of a TSO is akin to getting a TSO Authorization which is an FAA design and production approval issued to manufacturer that has successfully demonstrated meeting the performance requirements of the TSO - see CFR Part 21.601 and 21.603.  Do you really believe the FAA is going to allow manufacturers to claim they meet the performance requirements on the honor system?

[midlifeflyer]

I agree with Cruiser (Tom) above. To demonstrate meeting the "performance requirements" of a TSO is akin to getting a TSO Authorization which is an FAA design and production approval issued to manufacturer that has successfully demonstrated meeting the performance requirements of the TSO - see CFR Part 21.601 and 21.603.  Do you really believe the FAA is going to allow manufacturers to claim they meet the performance requirements on the honor system?

You mean like they do for GPS, transponders, Nav/Comms, HSIs, altimeters, etc intended for the experimental and LSA market? 

 

Maybe.

 

It's not a matter of believing something or not.