AeroVonics AV-20, clocks and minor mods

[ArtVandelay]

Ok, I found your clock, with seconds, in a panel mount, so now you all throw away you clocks:

[gsxrpilot]

3 minutes ago, jetdriven said:

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

The clock in my airplane now is the EI SC-5. With the push of a button, it will display Engine time instead of the clock, or a timer instead of the clock, or Zulu instead of local. That seems to be perfectly legal as well. And it doesn't display seconds with the clock, only with the timers. According to EI it's legal as a primary clock replacement. I'll have to go back through the logs to see when it was installed. 

I don't see how that's any different that my GPS which will display the time in one of the data blocks at the top of the screen at all times. For example, I don't have to turn off the map to get the clock. It's always there.

I've been ramp checked, no problems. Otherwise I've been through plenty of annuals, IFR certs, etc. Never a question. Of course, as they say, any airplane can be violated by any FSDO if he wants to. But I'm not losing any sleep over it. 

BTW... I've ordered the AV-20S. It's going in place of the EI SC-5 when it gets here.

[Jim Peace]

35 minutes ago, ArtVandelay said:

Ok, I found your clock, with seconds, in a panel mount, so now you all throw away you clocks:

I have the GTN myself. The question is how many pages deep is that ? And then I have to switch back to nav then the clock again etc. 

 

[gsxrpilot]

With the Avidyne's either 550/540 or 440, there are data blocks around the edge of the screen. They can be configured to always display the specific data you want, such as the time in either Zulu or Local.

[Andy95W]

44 minutes ago, gsxrpilot said:

With the Avidyne's either 550/540 or 440, there are data blocks around the edge of the screen. They can be configured to always display the specific data you want, such as the time in either Zulu or Local.

Paul, since the IFD always displays the time, I'm with you on this because of one sentence in the FAA legal explanation letter. It says pretty clearly that: "it is not necessary that the appliance's sole function be time-keeping."  

[jetdriven]

I agree. The data block time when it’s always displayed I think you can argue for.  but having to get 3 pages deep into a menu to View a clock while doing an approach that you’re actually using the GPS to do, seems a little far-fetched

[ArtVandelay]

I agree. The data block time when it’s always displayed I think you can argue for.  but having to get 3 pages deep into a menu to View a clock while doing an approach that you’re actually using the GPS to do, seems a little far-fetched

What approach type requires a clock (timer yes, but a clock, no)?

[Marauder]

What approach type requires a clock (timer yes, but a clock, no)?

Clock is not just used for timing approaches. It is also used for clearance void times, EFC and position reports.


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[ArtVandelay]

Clock is not just used for timing approaches. It is also used for clearance void times, EFC and position reports.

But none of those are high workload moments where going 3 screens to get to the gtn clock is going to be a problem.

[Marauder]

But none of those are high workload moments where going 3 screens to get to the gtn clock is going to be a problem.

 I agree, not a high workload environment.

 

It’s about the interpretation by the FAA Counsel that is the issue: “Your second question asks if an installed appliance that has a clock presentation will suffice for a clock. Another installed appliance with a permanent clock display that meets the requirements of§ 91.205(d)(6) that displays "hours, minutes, and seconds with a sweep-second pointer or digital presentation," is adequate for the purposes ofthis regulation.”

 

I interpret this to mean that the IFD displaying the clock permanently on the main screen meets the requirement but any device where you need to dig it out is not considered permanent. The interpretation of “permanent clock display” is what I would be concerned with. Does it mean the device needs to have the clock displayed all the time or just that it has a permanent clock in the device (which makes no sense, but then again who says these Regs have to make sense?)

 

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[gsxrpilot]

I've been noticing that almost no digital clocks display seconds with the time. They can display seconds with a timer but not on the clock. I wonder what the original clock was that Mooney installed in the 252 back in 1987? The EI SC5 that is installed now doesn't display seconds. 

[LANCECASPER]

24 minutes ago, gsxrpilot said:

I've been noticing that almost no digital clocks display seconds with the time. They can display seconds with a timer but not on the clock. I wonder what the original clock was that Mooney installed in the 252 back in 1987? The EI SC5 that is installed now doesn't display seconds. 

Well the clock picture doesn't show up in this article, but I remember reading this article in late 1985 as I was finishing up my private. 

 

[0TreeLemur]

On 12/22/2018 at 7:53 AM, Marauder said:

It’s about the interpretation by the FAA Counsel that is the issue: “Your second question asks if an installed appliance that has a clock presentation will suffice for a clock. Another installed appliance with a permanent clock display that meets the requirements of§ 91.205(d)(6) that displays "hours, minutes, and seconds with a sweep-second pointer or digital presentation," is adequate for the purposes ofthis regulation.”

 

Here's my take on this.   I replaced the Davtron clock with the clock/timer in the Aerovonics model AV-20-S that shows seconds, as a minor modification as is allowed by FAA letter 100S-GA-10-53.   This was confirmed as a minor change in non-transport category aircraft in FAA letter 100S-13-31.  The attached photo shows the format for the timer display, but the GMT and LCL time display options look exactly the same with HH:MM:SS as required by FAA 91.205.(d).(6) .  Period.

Incidentally, this AV-20S clock/timer that shows a digital representation of hours, minutes, and seconds, is also capable of showing a bunch of other information.  But it is fundamentally a clock.  The FAA has said that a clock need not have only time-keeping functions in order to be considered a clock.   It is widely accepted that the time representation on a GPS would be accepted as a clock if the seconds are shown.

Therefore, the AV-20 is a suitable clock for the purposes of 91.205.(d).(6) regardless of any NORSEE approvals.    I think a decent lawyer could convince a jury of that so I'm not worried about it. 

Edited December 28, 2018 by Fred_2O
English, clarity and a bit of detail.

[Marauder]

Here's my take on this.   I replaced the Davtron clock with the clock/timer in the Aerovonics model AV-20-S that shows seconds, as a minor modification as is allowed by FAA letter 100S-GA-10-53.   This was confirmed as a minor change in non-transport category aircraft in FAA letter 100S-13-31.  The attached photo shows the format for the timer display, but the GMT and LCL time display options look exactly the same with HH:MM:SS as required by FAA 91.205.(d).(6) .  Period.
Incidentally, this AV-20S clock/timer that shows a digital representation of hours, minutes, and seconds, is also capable of showing a bunch of other information.  But it is fundamentally a clock.  The FAA has said that a clock need not have only time-keeping functions in order to be considered a clock.   It is widely accepted that the time representation on a GPS would be accepted as a clock if the seconds are shown.
Therefore, the AV-20 is a suitable clock for the purposes of 91.205.(d).(6) regardless of any NORSEE approvals.    I think a decent lawyer could convince a jury of that so I'm not worried about it. 

Again, it comes down to the definition of the word the FAA used in their response. Permanent sounds like it means it is always being displayed.

Even the Aerovonics website points out that they are seeking out guidance. What they wrote on their site clearly indicates it is something that can be installed in addition to the required clock.

“Important Note: 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.)”

I’m not here to pee pee on the gizmo. As you know, I’m an early adopter on a lot of new technologies and would have one of these in my panel as a replacement to my clock if I felt it was a direct replacement today.

I got burned on a mod that was approved by one FSDO only to be told it needed to be removed by another.


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[MB65E]

But I did obtain an RVSM manual last Friday!

-Matt

[0TreeLemur]

 

18 minutes ago, Marauder said:

Again, it comes down to the definition of the word the FAA used in their response. Permanent sounds like it means it is always being displayed.

 

My attorney would argue that "Permanent" means that is affixed to the aircraft in a way such that it is "lasting or intended to last or remain unchanged indefinitely", which is the dictionary definition, as opposed to "Temporary" equipment everyone would agree an iPad-like device typifies because it is intended to be installed in the aircraft on an occasional basis and is not assured to be installed during every flight.  The flaw in the interpretation of "Permanent" put forth by @Marauder  stems from the fact that the Davtron M811B that I replaced did not display the time "Permanently" by his definition because it has modes to show the engine time, stopwatch, or whatever time it was set to.  The Davtron M811B would not pass @Marauder's definition of "Permanent".  However, because the M811B is certified, it is clear that a clock that meets 91.205.(d).(6) can have different modes other than showing the current time.

I have found the flight time display shown in the photo above very useful, as it helps me switch fuel tanks at the desired interval.  In a high workload environment, I could easily switch the display to the time and leave it there, and need no other function on that device.   Unless a vacuum failure occurred in IMC.  In that case I would (1) declare an emergency, (2) switch the AV-20-S to display its attitude information, and (3) ask the controller what time it was if I needed to know. 

BTW- I am not a lawyer but I have worked with a few from time to time, and I find them wonderful people to interact with and learn from.

[Marauder]

  My attorney would argue that "Permanent" means that is affixed to the aircraft in a way such that it is "lasting or intended to last or remain unchanged indefinitely", which is the dictionary definition, as opposed to "Temporary" equipment everyone would agree an iPad-like device typifies because it is intended to be installed in the aircraft on an occasional basis and is not assured to be installed during every flight.  The flaw in the interpretation of "Permanent" put forth by [mention=9886]Marauder[/mention]  stems from the fact that the Davtron M811B that I replaced did not display the time "Permanently" by his definition because it has modes to show the engine time, stopwatch, or whatever time it was set to.  The Davtron M811B would not pass [mention=9886]Marauder[/mention]'s definition of "Permanent".  However, because the M811B is certified, it is clear that a clock that meets 91.205.(d).(6) can have different modes other than showing the current time.

I have found the flight time display shown in the photo above very useful, as it helps me switch fuel tanks at the desired interval.  In a high workload environment, I could easily switch the display to the time and leave it there, and need no other function on that device.   Unless a vacuum failure occurred in IMC.  In that case I would (1) declare an emergency, (2) switch the AV-20-S to display its attitude information, and (3) ask the controller what time it was if I needed to know. 

BTW- I am not a lawyer but I have worked with a few from time to time, and I find them wonderful people to interact with and learn from.

 

 

The word “permanent” by itself would mean as you suggest. But when combined with the words “clock display”, as written in the FAA legal interpretation, it has a different meaning. “Permanent clock display”, means it displays the clock permanently.

 

You are also ignoring the manufacturer’s own website statement that clearly shows they are seeking guidance on the interpretation.

 

I doubt the boogie man is going to get you or anyone else who purchase one. Although in the 28 years of ownership, I have seen some strange, illogical requirements come and go. Like the Mode S mandate in the 1990s.

 

 

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[FastTex]

On ‎12‎/‎15‎/‎2018 at 9:28 AM, toto said:

You can say that again

Me three...I haven’t been excited about a small piece of kit like this in a long time but this thing looks really cool...;-)

[vorlon1]

After reading this thread, I wonder how many people like myself have seen perhaps a hundred kitchen timers velcro'ed to panels/yokes and their operators weren't loosing sleep over a ramp check...

[LANCECASPER]

1 hour ago, vorlon1 said:

After reading this thread, I wonder how many people like myself have seen perhaps a hundred kitchen timers velcro'ed to panels/yokes and their operators weren't loosing sleep over a ramp check...

However if you are planning on taking any kind of a check ride in the future, that one guy can make your life miserable.  Don't give him anything obvious to bust you on.

 

(I decided a few years ago to have a new CFI I know give me my Flight Review (not a check ride)  . .  give the kid a break, his first one ever, what could go wrong . . . don't make that mistake. He somehow thought it was a check ride and tried to make me fail before we ever got out of the FBO. No good deed ever goes unpunished . . .)

[gsxrpilot]

I'd still like to know what the original clock was in my 252. But the current clock, installed many years ago, is the EI SC-5. It's doesn't have seconds on the clock display, and can be toggled to display timers, or even Hobbs time. So it's definitely not "permanently displaying a clock".  I don't think your Davtron clock displays seconds either. And you can push buttons to display data other than the clock.

3 hours ago, LANCECASPER said:

However if you are planning on taking any kind of a check ride in the future, that one guy can make your life miserable.  Don't give him anything obvious to bust you on.

I took my instrument check ride with a kitchen timer Velcro'ed to the panel. We certainly used it to time holds and approaches, but the DPE didn't complain about it at all.

An AV-20S will go into my panel to replace the EI SC-5 at some point. And I won't lose any sleep over it. 

[aviatoreb]

https://www.amazon.com/LEGO-9001161-NINJAGO-Figurine-Alarm/dp/B00H3LR2YQ/ref=sr_1_27?s=home-garden&ie=UTF8&qid=1546030707&sr=1-27&keywords=clock+mini

[EricJ]

3 hours ago, aviatoreb said:

https://www.amazon.com/LEGO-9001161-NINJAGO-Figurine-Alarm/dp/B00H3LR2YQ/ref=sr_1_27?s=home-garden&ie=UTF8&qid=1546030707&sr=1-27&keywords=clock+mini

Everything is awesome!

[Ragsf15e]

I got the solution right here on my yoke!!  AV20 going in for stupid “Super Clock” and my 1968 windup clock even works!

[Captnmack]

This is what I use....