Are non-certified devices legal?

[bd32322]

I have seen aircraft with handheld gps mounts in the panel that receive power and antenna signals from the panel. Or nowadays there are ipad panel mounts.

By the same token, is providing power and sensor input to a garmin g3x MFD also legal? It seems to be a matter of degree. The non-certified MFD is not replacing any required gauges, but its an addition to the panel.

If it is indeed legal, then the gdu 375/ g3x is a very affordable MFD compared to the aspen. It can even display engine parameters. I suspect the problem with this approach will lie with interfacing the sensors to the engine etc. since those are not certified / STCed.

[jetdriven]

The FAA has pretty much ruled no field approvals on non-certified EFIS installations.

[Hank]

I thought non-certified stuff could be carried or non-permanently attached (not 'installed'), as long as the certified, installed avionics were still there for primary use. Isn't that how people 'mount' Garmin handhelds using those nifty removable mounts by I-forget-who?

[scottfromiowa]

NOPE

[Cruiser]

I believe the difference is that only the docking station is permanently mounted in the airplane. The actual equipment is removable. 

[bd32322]

Or the aspen mfd could display engine parameters .. that would solve my problem of paying twice for two glass things (JPI and Aspen) when technically just the MFD is all I need to display maps and engine parameters.

I dont see engine instrumentation listed as one of their features, however, a press release says they will add that functionality.

[jlunseth]

Sorry, but the question is muddy.  Legal for what?  If you are asking can I provide signals and power from my panel to a non-certified device, that would be up to your A&P who would add the port(s) but it should not be an issue.  I have a port to connect a portable Comm to my Ant 2 (Comm2) in the event of an emergency, and pretty much all of us who fly with iPads use the cigarette lighter for charging during the flight.

 

If the question is, can the non-panel device be used as a primary instrument to satisfy the various regs. for instruments required to be in the aircraft in order to fly VFR or IFR the answer is no.  The way you get to "no" is not necessarily simple however.  In the case of engine instrumentation such as MP and RPM, and some of the nav instrumentation, much of that equipment is specified in the Type Certificate for your aircraft, and must be in the aircraft and functioning, or a TSO'd replacement for the original instrument or an STC'd upgrade must be in the aircraft, or the aircraft is not airworthy.  In the case of instruments that the Type Certificate requires to be in the aircraft, an STC'd upgrade must not only be STC'd, it must be STC'd as primary for the instrument it replaces.  I am not aware of any portable devices that are STC'd as primary for any engine functions or for basic nav. functions.

 

Other regs. require basic instrumentation for VFR flight and for IFR flight.  Those regs. are not satisfied by having a portable instrument in the cockpit.

 

As far as IFR nav. by GPS is concerned, to use a GPS for IFR nav. it must comply with either TSO C129a or TSO C146 .  Both of these regs. require the equipment to be panel mounted.

 

A basic difference between portable equipment and certified equipment, is that the certified equipment is typically required to be part of a system that has an annunciator of some sort to detect and warn that the equipment is inoperable or not operating properly. 

 

Handhelds may be used to supplement installed and operating primary equipment, but the primary equipment must be there either for airworthiness, or to comply with regs. for a particular type of navigation. 

[bd32322]

Sorry, but the question is muddy. Legal for what? If you are asking can I provide signals and power from my panel to a non-certified device, that would be up to your A&P who would add the port(s) but it should not be an issue. I have a port to connect a portable Comm to my Ant 2 (Comm2) in the event of an emergency, and pretty much all of us who fly with iPads use the cigarette lighter for charging during the flight.

If the question is, can the non-panel device be used as a primary instrument to satisfy the various regs. for instruments required to be in the aircraft in order to fly VFR or IFR the answer is no. The way you get to "no" is not necessarily simple however. In the case of engine instrumentation such as MP and RPM, and some of the nav instrumentation, much of that equipment is specified in the Type Certificate for your aircraft, and must be in the aircraft and functioning, or a TSO'd replacement for the original instrument or an STC'd upgrade must be in the aircraft, or the aircraft is not airworthy. In the case of instruments that the Type Certificate requires to be in the aircraft, an STC'd upgrade must not only be STC'd, it must be STC'd as primary for the instrument it replaces. I am not aware of any portable devices that are STC'd as primary for any engine functions or for basic nav. functions.

Other regs. require basic instrumentation for VFR flight and for IFR flight. Those regs. are not satisfied by having a portable instrument in the cockpit.

As far as IFR nav. by GPS is concerned, to use a GPS for IFR nav. it must comply with either TSO C129a or TSO C146 . Both of these regs. require the equipment to be panel mounted.

A basic difference between portable equipment and certified equipment, is that the certified equipment is typically required to be part of a system that has an annunciator of some sort to detect and warn that the equipment is inoperable or not operating properly.

Handhelds may be used to supplement installed and operating primary equipment, but the primary equipment must be there either for airworthiness, or to comply with regs. for a particular type of navigation.

Thanks for the detailed post. My original post refers to an addition to and not a replacement of the required instruments. In other words, the equipment being added is not a primary at all.

By legal, I mean legally airworthy, i think, like how you explained.

I was asking is there a point between a handheld and an EFIS install where its not legally airworthy anymore. I think the answers above are in conflict.

[jetdriven]

The FAA has been very strict lately in regard to non-certified EFIS installations in certificated aircraft.  They will not grant field approvals even as a backup or for "advisory" use. Something has got their attention on this, but they have focused on this specific issue. Probably because they require connections to the pitot and static systems.

 

Here's a 6-page thread with 102 posts about the issue. Without an STC it ain't gonna happen.  http://www.beechtalk.com/forums/viewtopic.php?f=21&t=67018

 

The Dynon D1 is one way to work around this, but it cannot replace required instruments in certificated aircraft.  Be sure you can snap it out of the Air Gizmos mount when requested by an Inspector.

 

The same thing happened to HID landing lights. They want an STC or no field approval. We managed to install ours before that AFS-300 letter came out, in our log, its a minor alteration and log entry.

[PTK]

Or the aspen mfd could display engine parameters .. that would solve my problem of paying twice for two glass things (JPI and Aspen) when technically just the MFD is all I need to display maps and engine parameters.

I dont see engine instrumentation listed as one of their features, however, a press release says they will add that functionality.

Aspen had dreams about an engine monitoring display and a backup display but never materialized. It could've made a backup display for a G5/600.

http://www.aspenavionics.com/news/aspen_avionics_announces_more_new_products_for_2010/

[bd32322]

Aspen had dreams about an engine monitoring display and a backup display but never materialized. It could've made a backup display for a G5/600. http://www.aspenavionics.com/news/aspen_avionics_announces_more_new_products_for_2010/

Doh thats a shame and garmin g500 doesnt show engine instrumentation either.

[N201MKTurbo]

IFR with portable GPS... It goes like this...

 

Controller: I see you are /A, can you navigate to ABCDE intersection? wink wink (400 miles away)

 

Me: I can if you give me a vector.

 

Also FWIW Ded Reconing is a legal means of IFR navigation.

[jetdriven]

IFR with portable GPS... It goes like this...

 

Controller: I see you are /A, can you navigate to ABCDE intersection? wink wink (400 miles away)

 

Me: I can if you give me a vector.

 

Also FWIW Ded Reconing is a legal means of IFR navigation.

FAA FLIGHT PLAN

11. Remarks :  VFR GPS

 

You can navigate anywhere in the US with that. You just can't do approaches. it lowers the Controller's workload and yours. Try it. It even works in Canada, Mexico, and the Bahamas.

 

 

They see this note, and they ask "Can you go direct XYZ intersection" (600 miles away).  "Certainly."

 

"Cleared direct XYZ."

 

Filing /I used to allow you to go direct enroute to fixes with LORAN or INS capability.  I got my ass kicked when suggesting you file this with a KLN_89B VFR or a Garmin Aera in a panel dock. Filing /G guarantees IFR GPS enroute and approach capability. You obviously cannot do approaches with an Aera 500, but enroute is easy, so hence the VFR GPS notes.

[peter]

Aspen had dreams about an engine monitoring display and a backup display but never materialized. It could've made a backup display for a G5/600.

http://www.aspenavionics.com/news/aspen_avionics_announces_more_new_products_for_2010/

 

Aspen announced TSO for the backup display in March 2012, and shows the product on their website here: http://www.aspenavionics.com/products/evolution-backup-display

 

AFAIK, there is no aftermarket STC to this point, probably because no one has pursued one.  IMO, it's extremely capable equipment for the price, allowing non-Aspen equipped aircraft to upgrade their backups to an instrument that includes the capability to couple up to the autopilot and fly an instrument approach to minimums.  Just what you need when the "big screen" primary glass goes Tango Uniform.

[FloridaMan]

Legal or not, DO NOT COUNT ON THEM TO BE ACCURATE. I have observed things on the D1 and non-certified GPSs that could kill you if you were relying on them at the times I observed the failures. They're great for situational awareness, provided your certified instruments agree. 

[bd32322]

Legal or not, DO NOT COUNT ON THEM TO BE ACCURATE. I have observed things on the D1 and non-certified GPSs that could kill you if you were relying on them at the times I observed the failures. They're great for situational awareness, provided your certified instruments agree. 

Curious - can you give examples?

Thanks

[FloridaMan]

I have seen iPhone GPS report altitudes off by more than 1000 feet in sequential samples and I've seen my Dynon somehow decouple itself and dance around back and forth in 15-30 degrees of pitch and roll. 

[bnicolette]

I have seen iPhone GPS report altitudes off by more than 1000 feet in sequential samples and I've seen my Dynon somehow decouple itself and dance around back and forth in 15-30 degrees of pitch and roll. 

 

I can't say I've ever seen altitudes off by that much even in the flight levels but I suppose it's possible.  I have however seen "on video's" the dynon become quite erratic at times.  I thought they were supposed to address that issue though?  I can say without a doubt that I have never seen Foreflight running on the iPad mini or iPad 3 be anything but "dead nuts on" when comparing it to either a Garmin portable unit or even our Flight Management Systems while using an external GPS.  I can't speak to the internal GPS of the iPad except for use in the Mooney and they have always been "dead nuts on" also.

[jetdriven]

I have seen iPhone GPS report altitudes off by more than 1000 feet in sequential samples and I've seen my Dynon somehow decouple itself and dance around back and forth in 15-30 degrees of pitch and roll. 

Your GPS altitude is true altitude above sea level. The barometric altitude is pressure altitude corrected for non-standard pressure, but not non-standard temperature.  On the ground, they are about the same. At altitude, its off by a percentage. A few hundred feet off is normal.

[FloridaMan]

Your GPS altitude is true altitude above sea level. The barometric altitude is pressure altitude corrected for non-standard pressure, but not non-standard temperature.  On the ground, they are about the same. At altitude, its off by a percentage. A few hundred feet off is normal.

 

This is from sampling data and recording it on the iPhone. It'll make more sense later, but I've seen altitudes on short final 1500 ft or more than field elevation in the recorded data. 

[bd32322]

Your GPS altitude is true altitude above sea level. The barometric altitude is pressure altitude corrected for non-standard pressure, but not non-standard temperature. On the ground, they are about the same. At altitude, its off by a percentage. A few hundred feet off is normal.

GPS altitude has nothing to do with any earth reference altitude. What a GPS shows as altitude is derived from the distance of the GPS receiver from the center of a sphere formed by the GPS satellites. This is only a very approximate model because the earth is not perfectly spherical and the GPS satellite constellation has no way of knowing how high the earth's surface is from the imaginary GPS sphere's center.

So relying on GPS altitude is dangerous for real IFR flying.

The only ways a GPS receiver can get an accurate true altitude is by:

Knowing the height of the earth's true surface from the GPS model based on the receiver's horizontal position.

Receive signals from ground stations correcting the altitude calculation (WAAS I think)

And yes it will be true altitude.

[FloridaMan]

My experience more that the GPS on the iPhone is slow to respond with rapid changes in altitude. I have a feeling that it reports results based on a moving average of samples and not what it's actually reading. 

[Marauder]

I have been looking at the GPS altitude error issues on my Nexus 7 running Garmin Pilot. With the internal GPS active, I am getting a 300' to 400' difference consistently from my iPad using a XGPS150 running Garmin Pilot. Neither match the barometric corrected altitude in the plane. I have been seeing the same issue with the Nexus running the external XGPS150 and comparing it to the internal GPS. My next experiment is to see how far off the coordinates are using the different GPS signals. These "geo referenced" approach plates may be nothing more than "best guess" referenced approach plates.

[carusoam]

I have used the CloudAhoy app with internal and external Gps. The plot of the flight indicates a horizontal shift over the runway that is a clear inaccuracy. The external GPS Source seams to be a much better match.

But what does accuracy have to do with legal...

Yes it is legal to have my iPad on board. No it is not legal for primary nav.

It used to be illegal to have outdated charts on board...

Best regards,

-a-

[Marauder]

I have used the CloudAhoy app with internal and external Gps. The plot of the flight indicates a horizontal shift over the runway that is a clear inaccuracy. The external GPS Source seams to be a much better match.

But what does accuracy have to do with legal...

Yes it is legal to have my iPad on board. No it is not legal for primary nav.

It used to be illegal to have outdated charts on board...

Best regards,

-a-

 

Absolutely correct. But as a manufacturer of these apps why offer geo referenced charts if you know the position will be off? I have never used either my Nexus or iPad for navigation (that's why I spend all the big bucks on the panel), but it sure would be nice to know what degree of comfort you could have with them if all of that high priced electronic stuff goes "night night" because of an electrical problem.

 

That is what got me started on this. I always knew my portable GPS and now iPad/Nexus GPS altitudes were off a bit. I want to understand how far off the rest of the navigation stuff is even if I am not using it for navigation purposes.