AeroVonics AV-20, clocks and minor mods

[1964-M20E]

Warning Long post

Since I did not want to hijack the other thread any further I started a new thread.  I have always tried to interpret rules to let me do the most I can instead of interpreting them to be the most restrictive on what I can do.  Sometimes I'm right sometimes I'm wrong.

91.205 only states that the clock is required either analog or digital.  91.205 does not say the clock cannot do more than be a clock it just states one is necessary and does not actually state that it needs to be mounted anywhere.   Would a wrist watch suffice??

Aerovonics has NORSEE approval from the FAA for their AV-20 and since installing a clock can be a minor mod (see Davtron letter from FAA) I personally do not see any reason one could not use the AV-20 as a clock installed as a minor mod that has a few extra NORSEE features that can be pretty helpful in a bad situation.  After all that is what the whole NORSEE program is all about getting us newer technology that might be helpful and make flight safer.  The extra features are still for reference only.  To get the full use of the AV-20 you do need to connect to the pitot static system and that wold require a system check afterwards.

So we have NORSEE letter for the AV-20 to be installed as supplemental information and we have letter form the FAA stating the clocks in our planes are minor mods.  Spock maybe I am being illogical but I put the 2 of them together and the AV-20 can be my clock and NORSEE allows of the extra goodies and I the captain save the Enterprise once again.  Not to mention as TheTurtle stated we have so many clocks in or planes today just about every electronic device has one.

 

 

Clock as minor mod.pdf

1cqh4jsdj_19.pdf

With respect to clocks and 91.205 being required for IFR flight see below.

91.205

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:

(1) Instruments and equipment specified in paragraph b) of this section, and, for night flight, instruments and equipment specified in paragraph (c) of this section.

(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

(3) Gyroscopic rate-of-turn indicator, except on the following aircraft:

(i) Airplanes with a third attitude instrument system usable through flight attitudes of 360 degrees of pitch and roll and installed in accordance with the instrument requirements prescribed in §121.305(j) of this chapter; and

(ii) Rotorcraft with a third attitude instrument system usable through flight attitudes of ±80 degrees of pitch and ±120 degrees of roll and installed in accordance with §29.1303(g) of this chapter.

(4) Slip-skid indicator.

(5) Sensitive altimeter adjustable for barometric pressure.

(6) A clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation.

(7) Generator or alternator of adequate capacity.

(8) Gyroscopic pitch and bank indicator (artificial horizon).

(9) Gyroscopic direction indicator (directional gyro or equivalent).

 

Below is a letter from the FAA stating that installing clocks in small planes like ours is a minor mod.  I have attached a PDF file of the same letter and the letter can be found on Davtron's site.

U.S. Department of Transportation
Federal Aviation Administration
SEP 3 2010
In Reply
RetCr To: 1OOS-GA-l 0-53
Mr. Kevin Torresdal
President
Davtron. Inc.
427 Hillcrest Way
Emerald I Iilis. CA 94062
Dear Mr. Torresdal:
Transport Airplane Directorate Aircraft Certification Service
1601 Lind Avenue Southwest
Renton, Washington 98057-3356

This is in response to your letter dated August 24. 2010 regarding the installation of
replacement clocks in small airplanes. We consider the installation of replacement clocks
(including timers and stopwatches) in non-transport category airplanes to be minor changes
in accordance with Title 14 Code of Federal Regulations (CFR) section (~) 21.93(a). Per
CFR S 21.95. copies of this letter may be given to installing mechanics as evidence that this
installation is considered minor. The installation should be documented using a
maintenance log book entry referencing this letter.
Ii"you have questions regarding any oi"the above issues. please contact me at telephone
number (425) 917-6405. or by electronic mail at jellmorfitt({/li"aa.gov.
Sincerely.
Jeffrey A. Morfitt
Small Airplane Program Manager
Seattle Aircraft Certification Oflice

 

@Bob Stephens respectfully disagrees with me regarding installing the AV-20 as the required clock. (from another thread)

You interpret that differently than I do.  91.205.(d).(6) requires a clock with a sweep second hand or digital equivalent for instrument flight.  NORSEE allows installation in addition to, not in replacement of, required instruments.  The Aerovonics page does not say that only parts of the instrument are NORSEE approved.  The entire instrument is NORSEE approved.  The way I interpret that is that I could keep my clock and add the AV20-S, but I cannot use the AV20-S to replace my clock.  That's why I'm waiting for Aerovonics to get approval for use as a required clock.  While using the AV20-S to replace a clock meets the spirit of the law, I do not think it meets the letter of the law.  Is anyone going to say something?  Probably not.  Will it ever matter?  Highly unlikely that a clock would have anything to do with an accident/incident.  But I want to comply with the letter of the law.  That's why we also installed a nav source indicator for our GTN650 so we could legally fly IFR.

My GTN650 will display time, but only hours and minutes unless I want to dig all the way down through the menus to a settings page.  It will show me a timer including seconds, but the requirement is not for a timer, but a clock.

 

@TheTurtle

from another thread

NORSEE allows installation *in addition to* existing, required instruments in the cockpit.  We are working guidance on how to potentially replace a legacy, analog clock which may be considered a required instrument in some aircraft.  (GPS units often have a clock that meets FAR requirements.)

 

That toaster you are berating and being mean too was your ticket to IFR.  I think you should apologize to her.

With your updated panel you probably have another clock

 

[vorlon1]

Nice post and summary. Looking forward to seeing the responses.

[orionflt]

my airplane did not come equipped with a clock back in 1961/62, I had a battery powered digital clock that has a clip to meet the IFR requirements. I now have a clock in the GTN 430 MVP-50 AV-20 my Iphone and Ipad, not to mention timers on all the above and my GTX 330. I think i meet all the requirements.

If you go back to the reason for a time source, it was to time your legs and turns to ensure you were in the general location you should be based on your flight plan. with all the electronics that we have installed in our planes with the GPS time sources and timers we exceed the basic requirements set way back when IFR was done solely by dead reckoning and an occasional ground fix.

Brian 

 

 

[gsxrpilot]

I'm with you on this, @1964-M20E. While it's pretty low on my list of priorities, I will likely at some point, replace the EI clock in my panel with the AV-20S. 

[Marauder]

I will let one of the IAs comment on my thought here. I think the reference on their website pertaining to handling analog clocks is for planes that have a MEL or is part of the type certificate and the clock is spelled out on that list.






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[Hank]

2 hours ago, orionflt said:

If you go back to the reason for a time source, it was to time your legs and turns to ensure you were in the general location you should be based on your flight plan. with all the electronics that we have installed in our planes with the GPS time sources and timers we exceed the basic requirements set way back when IFR was done solely by dead reckoning and an occasional ground fix.

That could all be done with a TIMER.

But a CLOCK is needed for IFR releases and further clearances. "If not off the ground by 20 minutes past the hour, release is canceled--call me back", etc., when departing non-towered fields under IFR.

[carusoam]

And timed approaches from a VOR to going missed...  this needs seconds being displayed.

Having an Approach rated GPS pretty much eliminates the timed approach. (?)

Best regards,

-a-

[jetdriven]

11 hours ago, nosky2high said:

I concur with this analysis. Installing a new clock/voltmeter/OAT that is also a backup solid state attitude indicator with AOA for under $1000 is an outstanding value for the vintage panel IFR flyers out there.

I haven’t been excited about a small piece of kit like this in a long time but this thing looks really coolI haven’t been excited about a small piece of kit like this in a long time but this thing looks really cool

[toto]

12 hours ago, jetdriven said:

I haven’t been excited about a small piece of kit like this in a long time but this thing looks really coolI haven’t been excited about a small piece of kit like this in a long time but this thing looks really cool

You can say that again

[Bob - S50]

Just more info.  You can all do what you like (obviously) but I'm still going to wait until the AV20-S is approved for replacing a required clock before I install it.  Along those lines I wrote to them and asked:

" (me) Any update on the possibility of the AV20-S being used as a required clock? Thanks, Bob

 

Hi Bob,

 

We plan on testing the AV-20 along with the AV-30 during qualification, so that we can eventually bring the AV-20 to the market as a full PMA’ed product (versus a NORSEE approval).  This will allow replacement of the clock.  It’s a lower priority at the moment however, so it’s probably over a year out.

 

Jeff"

[Jim Peace]

On 12/14/2018 at 5:57 AM, 1964-M20E said:

 

(6) A clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation.

 

I want to see the seconds in a minute.  How else do you know how far in the minute you are?

It is a crime that most of these manufactures do not show clocks on their products, Ex: GTN650, JPI 900, etc...

I really want the panel mount CO/clock combo from guardian but they do not show seconds.  Why the F not....

https://www.guardianavionics.com/aero-553-panel-digital-display-multi-function-co-detector-tso-certified-aircraft

I emailed them about how they got certified etc and wanted to know more about it and they will not email back....

Sticking with my 2 dollar panel mount analog clock until a manufacturer can get it right.

 

 

[ArtVandelay]

I want to see the seconds in a minute.  How else do you know how far in the minute you are?

It is a crime that most of these manufactures do not show clocks on their products, Ex: GTN650, JPI 900, etc...

The GTN has a timer page, my transponder (KT74) has a timer(they call it a stopwatch), 2nd nav (GNC255) has timer functionality (up/down).

I would not use the GTN since if I’m using a timer it’s because my GTN is not working and would use the 255 as my backup.

Maybe it should be a crime when users don’t read the manuals!

:-)

[gsxrpilot]

1 hour ago, ArtVandelay said:

The GTN has a timer page, my transponder (KT74) has a timer(they call it a stopwatch), 2nd nav (GNC255) has timer functionality (up/down).

I would not use the GTN since if I’m using a timer it’s because my GTN is not working and would use the 255 as my backup.

Maybe it should be a crime when users don’t read the manuals!

:-)

Timers are not clocks. You might have missed that bit.

[ArtVandelay]

Timers are not clocks. You might have missed that bit.

Opps, yes, but does that need to be panel mounted in this day and age with phones, etc.? Isn’t the clock is only needed for pilot reports and hold exit times and with the later they give you the current time so you could use a timer?

[gsxrpilot]

Yeah, I'm in the group that doesn't believe a panel mounted clock is required equipment. But there is a sizable group on the other side of the issue as well.

[Jim Peace]

Is it really so hard to get a clock that displays seconds? My Casio does it.  

I finally got in touch with guardian today about their panel mount clock/co monitor. He said I can only see seconds in stop watch mode. 

I will see what davtron has, does anyone know if they have one that displays time with seconds?  They did have a model I wanted that showed both local and UTC with seconds but it always says under development on their site. 

[gsxrpilot]

I know what you're saying. 

EI has one called the SC-5 (Super Clock). https://buy-ei.com/portfolio/sc-5/

They claim its a primary replacement for a OEM clock even though it doesn't display seconds either. 

Full disclosure... I have one and don't like it at all.

[Steve W]

It appears that there are almost 0 of the digital clocks on the aircraft spruce clock page that simultaneously display seconds. Well, except the $500 midcontinent one that comes with USB ports too...

Edited December 21, 2018 by Steve W

[gsxrpilot]

If anyone wants an EI SC-5... I'll pull it out and sell it. EI claims its certified primary.

I'll replace it with an AV-20S and not think twice about it.

[Marauder]

It appears that there are almost 0 of the digital clocks on the aircraft spruce clock page that simultaneously display seconds. Well, except the $500 midcontinent one that comes with USB ports too...

I guess I should be happy that I installed the Davtron M877 back when they were less than $250.




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[jetdriven]

2 hours ago, gsxrpilot said:

Yeah, I'm in the group that doesn't believe a panel mounted clock is required equipment. But there is a sizable group on the other side of the issue as well.

You may want to read this.  

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/data/interps/2016/Nkugba - (2016) Legal Interpretation.pdf

[gsxrpilot]

7 minutes ago, jetdriven said:

You may want to read this.  

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/data/interps/2016/Nkugba - (2016) Legal Interpretation.pdf

Yeah, I've seen that. All that says is that a wrist watch doesn't satisfy the requirement for IFR flight. I'm still of the personal opinion that there are a lot of options within the guidelines in this document.

[jetdriven]

4 minutes ago, gsxrpilot said:

Yeah, I've seen that. All that says is that a wrist watch doesn't satisfy the requirement for IFR flight. I'm still of the personal opinion that there are a lot of options within the guidelines in this document.

As long as it’s a  panel mounted clock that shows hours minutes and seconds, I think you’re right. That is from the office of chief counsel..that’s as high as it goes in that department. Do you really want to play lawyer games about definitions with them on administrative law? 

Anyway what do you suggest in Lieu of a panel mounted clock?

Edited December 21, 2018 by jetdriven

[gsxrpilot]

10 minutes ago, jetdriven said:

As long as it’s a  panel mounted clock that shows hours minutes and seconds, I think you’re right. That is from the office of chief counsel..that’s as high as it goes in that department. Do you really want to play lawyer games about definitions with them on administrative law? 

Anyway what do you suggest in Lieu of a panel mounted clock?

I'm not arguing with the document at all. I'm just saying that it leaves plenty of room for options... such as my IFD540. It displays Local/Zulu or both with HH:MM:SS. 

[jetdriven]

I guess it boils down to what your definition of a “permanent clock presentation” is, and how defensible that is.