Non TSO'd instruments in certified aircraft

[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?

[peter]

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?

[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?

[peter]

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?

[Geoff]

Thanks again.  I appreciate the insights.

[M016576]

Quote: peter

No, this configuration is specifically disallowed under the STC for certification reasons.  The ability to switch an MFD1000 from PFD to an MFD would allow the primary display of attitude, airspeed and altitude to be supressed, which is specifically against FAR 23.1311(a)(3).  When an EFD1000 PFD is installed, the PFD is the primary display and the MFD is secondary. Whenever an EFIS is installed, the FAA always considers it as the primary display, so mechanicals can't be counted for compliance to this rule.

One reason why the MFD1000 is less expensive than a PFD is precisly because a PFD must also be installed, and we (Aspen) don't like to double dip on our customers (I know, it's a shocking departure from tradition!). 

[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?

 

 

[danb35]

Well, the 696, Aera, etc., aren't "installed" in the plane.  There's a plastic cover plate in the panel, which happens to fit the shape of the device, and a "test cable" connected to aircraft power, the end of which happens to fit the power connector of the device.  The device itself snaps in and out, no installation.  To install a device, you have to have some approval to do so, which isn't present for the non-certified instruments out there--at least that's my understanding.

[peter]

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?

[Tom]

Quote: peter

I've seen, however, signs that the FAA is starting to get concerned as the panel docked GPS' have grown in size and capability, even more so as they get installed in such prominent positions that they are supplanting approved equipment.  I hear rumblings that the FAA may be rethinking their position on this subject. Time will tell.

[peter]

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

[peter]

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).

[tony]

I love this conversation; we have it at work every now and then.  We never seem to come to a consensus.  I have looked for FAA guidance on this, an AC, a position paper, something; and I cannot find anything published.  That’s why I am very interested your letter.  Peter I just brought up the DME example because King used to market a KN-62 and a KN-62a.  One had the TSO, and one didn’t.  The units were identical on the outside, operation, totally transparent to the user.  One was supposed to have been marketed to the experimental guys and the other for certificated aircraft.  I would guess that a lot of Non TSO’d units found their way into certificated aircraft.

Peter, I fully understand all of the hoops you have to jump through for your products and frankly your company provides an amazing value.  I just keep getting back to the place that if you are not affecting the cert basis with a modification (your products definitely do), and the modification in question  adds a system that does just that,  provides a larger margin of safety and better situational awareness; where it is written that it has to have a TSO or PMA?

 

[Piloto]

Quote: peter

As someone who knows the TSO testing requirements first hand, let me say that they are very demanding.  That's not to say that uncertified equipment can't meet TSO, but if they could, why not get the TSO?  TSO is more than just meeting a performance standard, its about showing that the equipment meets that standard at the extremes of temperature, altitude, humidity, and vibration.  That the equipment doesn't interfere with other equipment, or get interfered with.  That the equipment will opreate correctly through voltage spikes and transients, withstand the direct and indirect effects of lightning, and survive encounters with RF radiation that are likely to sterilize the pilot.   One example of a test the Aspen display needed to survive was 10 direct lightning strikes, with continued normal operation, no resets, no failures, during and after each strike.   Maybe you don't think this matters, but trust me, the day you get hit by lightning it wil be the only thing that matters.

[Tom]

Quote: peter

Having said that, that is not to say there is no risk in deregualting.  I also can't agree that there is no evidence to support TSO over non-TSO. The NTSB database has many accident reports where use of unapproved equipment contributed to the accident.  Homebuilt aircraft also have a much worse safety record than certified aircraft. 

Let's not forget that the certification rules for part 23 are there primarily for folks who have paid to fly in that aircraft, whether its sightseeing, flight training, or transit.  Those folks have an expectation of arriving safely at their destination, and the rules are there to assure that. 

As someone who knows the TSO testing requirements first hand, let me say that they are very demanding.  That's not to say that uncertified equipment can't meet TSO, but if they could, why not get the TSO?  TSO is more than just meeting a performance standard, its about showing that the equipment meets that standard at the extremes of temperature, altitude, humidity, and vibration.  That the equipment doesn't interfere with other equipment, or get interfered with.  That the equipment will opreate correctly through voltage spikes and transients, withstand the direct and indirect effects of lightning, and survive encounters with RF radiation that are likely to sterilize the pilot.   One example of a test the Aspen display needed to survive was 10 direct lightning strikes, with continued normal operation, no resets, no failures, during and after each strike.   Maybe you don't think this matters, but trust me, the day you get hit by lightning it wil be the only thing that matters.

[tony]

We need to stick to what the regs say.  I’m pretty sure engine instruments were required by CAR 3.  Geoff’s original question was, can he leave his original instruments in the cockpit and add a non TSO instrument to enhance his situational awareness?

[peter]

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

 

[rogerl]

Quote: danb35

Well, the 696, Aera, etc., aren't "installed" in the plane.  There's a plastic cover plate in the panel, which happens to fit the shape of the device, and a "test cable" connected to aircraft power, the end of which happens to fit the power connector of the device.  The device itself snaps in and out, no installation.  To install a device, you have to have some approval to do so, which isn't present for the non-certified instruments out there--at least that's my understanding.

[Piloto]

Quote: peter

The RF environment is 150V/m of RF energy over a broad spectrum. No, its not a nuclear explosion, but is more than I ever want to be exposed to.  People are not allowed inside the test chamber during this testing because of the hazard.

DO160 standards are rigourous, in fact, often cited by the Military these days as acceptable for installation in military aircraft.   I raise this point to differentiate TSO from non-TSO. TSO equipment has been shown to meet a accepted standard. Non-TSO  has not.

[peter]

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?

[M016576]

Quote: peter

Hi Job,

Thanks for sharing your thoughts.  As much as I wish we could sell our displays for less, we need to make enough money to stay in business. As volumes continue to increase I expect we’ll be able drive our costs down, and hopefully pass some savings on to our customers.

When it comes to pricing, please don't forget that before Aspen, a certified retrofit EFIS system cost between $30k and $80k.  Now Aspen offers this capability starting at $6k – accessible even to the “little guy.”  The Evolution system shattered the established price floor for EFIS technology and has led the old guard to rethink their pricing strategies and to seriously cut their prices to compete (or perhaps they are just trying to run us off so they can jack their prices again?).

The price differences between PFDs and MFD are explained by our cost differences to produce these systems, and the economic value of the software functionality they provide.  For example, the MFD costs less to produce because it doesn’t come with an analog converter or emergency GPS.  Further, it can only be installed along side a PFD, so there is a volume cost efficiency there. These factors allow us to sell the hardware for less.  

Software value also gets factored into the price of the equipment. Aspen has invested tens of millions developing the EFD1000 hardware and software over the past 6 years. Like all businesses, we amortize these development costs over future sales.  When you think about it, even though the MFD1000 is capable of being both a PFD and an MFD, we only charge for the MFD functionality.  If we were to charge a customer for both the PFD and the MFD functionality, then an MFD1000 should cost more than a PFD, not less.  Our philosophy was that since an MFD100 installation is only possible if there is also an installed PFD, then the customer has already paid for the PFD functionality and we don’t charge them again for it in the MFD1000 -  i.e., no double dipping.

The same types of concepts are applied to our Pilot product.  It costs us less to produce, and it has a basic software feature set, so it gets a basic price to match.

I don't want to get into a debate on pricing philosophies, but I do hope this little bit of insight helps explain how we have approached it at Aspen.

[peter]

Quote: M016576

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

[M016576]

>>>Quote

: M016576

[peter]

Quote: M016576

[tony]

Quote: danb35

Well, the 696, Aera, etc., aren't "installed" in the plane.