Synopsis anyone? Haven't had time to read it through yet. But from my first glance, it appears that we are in trouble if Navworx doesn't cooperate and come up with some solutions that the FAA agrees with.
Van's Air Force
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Possible AD for certain NAVWORX ADS-B Units
- Thread starter GalinHdz
- Start date
OK - so the AD is out on the streets...the way I read it, within 6 months of July 11th (Jan 11, 2018 - give or take a day!), the 0012, 0013, and 8013 PN's are useless in that state.
You can't get an upgrade of the internal GPS until after 1 July - then Dallas Avionics will be busy ($599 more for us early adopters)...do we know that this upgrade will turn our units in to 0112/0113 and 'certified' EXP boxes? Then more money to put in the second GPS antenna for the upgraded box...customers are currently on the hook for both of these!
Is anyone pursuing the use of the 400W/500W, 600/700, or 480 as a certified external solution? If these are certified for approaches and contain the software to output the proper data stream - we should be able to use them.
I plan to request the use of my 430W as an Alternate Method of Compliance and see what they say. I'll update with their response!
You can't get an upgrade of the internal GPS until after 1 July - then Dallas Avionics will be busy ($599 more for us early adopters)...do we know that this upgrade will turn our units in to 0112/0113 and 'certified' EXP boxes? Then more money to put in the second GPS antenna for the upgraded box...customers are currently on the hook for both of these!
Is anyone pursuing the use of the 400W/500W, 600/700, or 480 as a certified external solution? If these are certified for approaches and contain the software to output the proper data stream - we should be able to use them.
I plan to request the use of my 430W as an Alternate Method of Compliance and see what they say. I'll update with their response!
rleffler
Well Known Member
I was going to do the same for my GTN650. If you read the comments that the FAA published last week, it stated the Garmin told them that the 480 wasn't compliant.
I'm not optimistic at the moment, the AD appears to be harsher than I anticipated. It also doesn't paint a clear path with the Navworx announced upgrades. Navworx still has to prove to the FAA that the new units are compliant. Based upon their track record, I'm not sure what to expect.
JohnAJohnson
Member
My question too. Just because Navworx says it will make things 2020 compliant doesn't make it so. Fool me once (ADS600-B), Fool me twice (GNS430W)...
And here's another question.... I cannot see anyway that the exchange boxes will carry the 112/113 part numbers. Will the new boxes, with their new part numbers be eligible for the $500 rebate (if installed before the September cutoff)? Will the FAA consider the 012/013 boxes as legitimate ADS-B installations, thus nullifying the second dip at the well for rebate purposes?
I see lots of ADS-B systems authorized to use the 430W as a position source at the FAA site and a lot of systems that aren't. This tells me that Garmin or other WAAS equipment isn't an automatic shoe-in as a position source but must be certificated WITH the specific ADS-B box. Insanity that would probably take a company two years and a wheelbarrow full of money to do.
I can't see an individual getting an AMOC for the 430W, but if you were to do it and have it approved, it should open the door for everyone else to do it. Press on and please keep us posted!
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Jordan1976
Well Known Member
If the aircraft has ever transmitted ADS-B OUT before, it is not eligible for the rebate. Doesn't matter if the previous ADS-B was compliant or not, certified or not.
DavidBunin
Active Member
The way I read it, the AD is effective July 11 and compliance required in six months. December is the sixth month after July, so action must be taken by December 31, 2017.
The FAA waited a long time to publish this AD. I would guess that they have reached some internal point in the approval process for the new NavWorx products.
I think there will be multiple paths forward by the end of this year. Let's see what announcements are made at Oshkosh.
Link to the AD
Since I have not seen anyone post the link to the AD on the FAA website, here is where you can download the actual FAA AD document.
Since I have not seen anyone post the link to the AD on the FAA website, here is where you can download the actual FAA AD document.
Good clarification in the AD. About what I expected.
Summary of what happened with the NavWorx boxes:
- NavWorx released ADS-B boxes with an uncertified GPS chip, using a SIL of 0. The FAA was fine with this.
- The FAA decided that units using a SIL of 0 shouldn't get traffic. (why??)
- NavWorx published a software patch to change their SIL from 0 to 3 without actually ensuring their hardware/software was SIL 3 compliant.
- The FAA has rejected this change due to non-compliance, thus the AD.
Re: 430W and GTN650: It is up to NavWorx to confirm performance compliance with those GPS sources, which NavWorx has not done. It would be interesting to see if you can get field approval for that pairing - though I would expect you'd have to show proof of compliance too.
Summary of what happened with the NavWorx boxes:
- NavWorx released ADS-B boxes with an uncertified GPS chip, using a SIL of 0. The FAA was fine with this.
- The FAA decided that units using a SIL of 0 shouldn't get traffic. (why??)
- NavWorx published a software patch to change their SIL from 0 to 3 without actually ensuring their hardware/software was SIL 3 compliant.
- The FAA has rejected this change due to non-compliance, thus the AD.
Re: 430W and GTN650: It is up to NavWorx to confirm performance compliance with those GPS sources, which NavWorx has not done. It would be interesting to see if you can get field approval for that pairing - though I would expect you'd have to show proof of compliance too.
Back on posts #500 and 501, there were comments stating this AD cannot apply to an experimental. Unfortunately ADs can apply to experimentals, and this one does. The FAA clarifies this on page 8 as follows:
Request: EAA and two individual commenters requested the AD not apply to experimental or light sport aircraft, since they are not regulated in the same manner as type-certificated aircraft. EAA states the FAA should address any valid airworthiness concerns with parts intended for experimental aircraft through a Special Airworthiness Information Bulletin (SAIB) or safety alert for operators (SAFO). Two commenters requested the AD apply to experimental aircraft, because those aircraft operate in the same airspace as type-certificated aircraft and should use equipment with the same integrity. A few commenters, including AOPA, requested we clarify whether the AD applies to experimental aircraft.
FAA Response: We agree to clarify this issue. We confirm that the AD applies to all aircraft, including experimental, and we revised the AD to clarify the applicability. We made this AD applicable to the ADS600-EXP P/N 200-8013 units because the design of the Model ADS600-EXP P/N 200-8013 is substantially identical to the Model ADS600-B P/N 200-0012 and 200-0013, specifically with regard to the internal GPS and the SIL setting. While some commenters are correct that the FAA has chosen to minimize regulations on experimental aircraft because of the level of the safety risk, these risks normally apply to the individual airplane and do not affect the overall NAS. The safety risks defined in this AD extend beyond one aircraft and could affect many other aircraft as well as ATC. Therefore, we find it necessary to include experimental aircraft in the AD's applicability.
We do not agree that an SAIB or SAFO would be an appropriate solution. These documents contain information and recommended actions that are voluntary and not regulatory. Moreover, an SAIB is issued only for airworthiness concerns that do not rise to the level of an unsafe condition.
The mission of the FAA is aviation safety. ADs are used by the FAA to correct known safety defects. It would be contrary to the intent of the FAA's mission and statutory authority to exclude certain aircraft when we have determined that a part installed on those aircraft has a safety problem.
Request: EAA and two individual commenters requested the AD not apply to experimental or light sport aircraft, since they are not regulated in the same manner as type-certificated aircraft. EAA states the FAA should address any valid airworthiness concerns with parts intended for experimental aircraft through a Special Airworthiness Information Bulletin (SAIB) or safety alert for operators (SAFO). Two commenters requested the AD apply to experimental aircraft, because those aircraft operate in the same airspace as type-certificated aircraft and should use equipment with the same integrity. A few commenters, including AOPA, requested we clarify whether the AD applies to experimental aircraft.
FAA Response: We agree to clarify this issue. We confirm that the AD applies to all aircraft, including experimental, and we revised the AD to clarify the applicability. We made this AD applicable to the ADS600-EXP P/N 200-8013 units because the design of the Model ADS600-EXP P/N 200-8013 is substantially identical to the Model ADS600-B P/N 200-0012 and 200-0013, specifically with regard to the internal GPS and the SIL setting. While some commenters are correct that the FAA has chosen to minimize regulations on experimental aircraft because of the level of the safety risk, these risks normally apply to the individual airplane and do not affect the overall NAS. The safety risks defined in this AD extend beyond one aircraft and could affect many other aircraft as well as ATC. Therefore, we find it necessary to include experimental aircraft in the AD's applicability.
We do not agree that an SAIB or SAFO would be an appropriate solution. These documents contain information and recommended actions that are voluntary and not regulatory. Moreover, an SAIB is issued only for airworthiness concerns that do not rise to the level of an unsafe condition.
The mission of the FAA is aviation safety. ADs are used by the FAA to correct known safety defects. It would be contrary to the intent of the FAA's mission and statutory authority to exclude certain aircraft when we have determined that a part installed on those aircraft has a safety problem.
Hopefully between July and the required implementation date, we can get my SL-70 control head issue fixed - then I can get in line to hopefully get my unit converted from a -0013 to a -0113.
Not really a fan of chasing money with money - but the AD does not apply to the -0113 units and I like the functionality combination...starting with the SL-70 control head working at 1200 Baud.
Go, Bill, GO!
Not really a fan of chasing money with money - but the AD does not apply to the -0113 units and I like the functionality combination...starting with the SL-70 control head working at 1200 Baud.
Go, Bill, GO!
DennisRhodes
Well Known Member
Guess NW has already thought of this but why not pursue getting the GPS position source they are now using TSOd or at lease prove it to be of equal performance for use in the EXP units ( Which we thought had already happened). That might would allow the EXP units to operate JAN 1 2020. Seems the FAA was not concerned with the accuracy but rather the integrity (or failure method) on the "commercial" GPS source. I know there are many FAA reports that indicate accuracy is within limits. I know I have a couple. Looks like that might would be a better route than than replacing.
My other question : How is it other manufactures are advertising certified GPS position sources and also advertising an output of SIL= 3 but do not show up on the approved list that's on the FAA site. ie echo UAT uavonix , and the GRT/ Dynon position source maybe others? Are they good for compliance in 2020 or just next in line?
As for the other experimental use units that advertise 2020 compliant, do they offer a letter or certification indicating the FAA has approved their position source. Anyone seen one?
My other question : How is it other manufactures are advertising certified GPS position sources and also advertising an output of SIL= 3 but do not show up on the approved list that's on the FAA site. ie echo UAT uavonix , and the GRT/ Dynon position source maybe others? Are they good for compliance in 2020 or just next in line?
As for the other experimental use units that advertise 2020 compliant, do they offer a letter or certification indicating the FAA has approved their position source. Anyone seen one?
1. As I read the AD, the FAA is concerned with the ability of the GPS to detect a failure in the satellite system, among other things. It's not JUST the gps' integrity, it's the whole system.
2. The boxes you mention are NOT "certified" (e.g., they do not carry a TSO tag) and by FAA fiat they are not on the approved list to qualify for a $500 rebate. The manufacturers state that they "meet the standards" and therefore are eligible for installation (within the limits set forth in their documentation) on EAB aircraft. Note the gps source must only use transmitters listed in the documentation.
3. I know of no FAA list of "approved but not TSO'd" devices, so I think you're taking it on faith that the manufacturer really has talked with the FAA, provided all needed data, and gotten an okay. It's most unfortunate that faith in Navworx appears to have been misplaced.
Paul 5r4
Well Known Member
Navworx 600 EXP models
I have the navworx 600 EXP model... There for awhile I was beginning to get the impression the FAA was going to leave the EXP models out of the AD. That's not the case. I just called the number listed on the Navworx site and connected to a very nice gentleman from Dallas Avionics. I ask what I needed to do to get the unit to comply with the AD. I'll relay his comments here. He stated he was actually on the way to a meeting with navworx today about the AD and how to bring all this to a close for everyone affected. He did say there are plans in place and it's not the end of the world. He ask that I call him back tomorrow as he should have some answers for me/us then. Hopefully some good information will come tomorrow. I will call him and post any information here.
I have the navworx 600 EXP model... There for awhile I was beginning to get the impression the FAA was going to leave the EXP models out of the AD. That's not the case. I just called the number listed on the Navworx site and connected to a very nice gentleman from Dallas Avionics. I ask what I needed to do to get the unit to comply with the AD. I'll relay his comments here. He stated he was actually on the way to a meeting with navworx today about the AD and how to bring all this to a close for everyone affected. He did say there are plans in place and it's not the end of the world. He ask that I call him back tomorrow as he should have some answers for me/us then. Hopefully some good information will come tomorrow. I will call him and post any information here.
DennisRhodes
Well Known Member
Still confused, So does this mean I need to have my EXP unit reprogramed to an SIL =0 and then the FAA will allow my experimental aircraft into Class C and under Class B airspace even though the internal source is uncertified? Except that I won't be able to receive any TIF and that will be safer?? Or does the access to Class C and under Class B go away with the change in SIL? If that is true why would I want to carry a brick around all the time?
DavidBunin
Active Member
Understandable. The thing to do right now is nothing. Wait and see what announcements are made at Oshkosh.
Yes, changing to a SIL of 0 is one potential solution acceptable to the FAA, but I think probably not acceptable to many aircraft owners. Wait and see what's behind door number two.
DennisRhodes
Well Known Member
roadrunner20
Well Known Member
Ok, Let me get this straight.
The FAA wants me to disconnect my ADS-B box in 6 months that I have received multiple in-compliance reports from their agency, because it may not be as accurate or may suffer a breakdown in flight and misreport my position in the NAS.
They will not allow me to use it until the actual compliance date in 2020, because it may present a NAS safety issue to me or other aircraft.
So they want me to unplug it and transmit NO position & receive NO position on any aircraft in the NAS. Safer or Not Safer?
The FAA wants me to disconnect my ADS-B box in 6 months that I have received multiple in-compliance reports from their agency, because it may not be as accurate or may suffer a breakdown in flight and misreport my position in the NAS.
They will not allow me to use it until the actual compliance date in 2020, because it may present a NAS safety issue to me or other aircraft.
So they want me to unplug it and transmit NO position & receive NO position on any aircraft in the NAS. Safer or Not Safer?
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Paul 5r4
Well Known Member
One method of the AD compliance states to change the SIL back to 0. If I'm understanding the result of a SIL change from 3 back to 0 on the EXP units and that will NOT allow 600 EXP users to receive traffic information... well, what's the point of having the thing in the plane at all???
What would you rather have: no position reported, but you have your fallbacks to find aircraft (eg: eyeballs, radar), or: a bad position reported but indicating its a good position, so you think it's at position A when its really at position B?
DennisRhodes
Well Known Member
For VFR flight and (Assuming you have a Navworx that has lost its intergity!) a default to "no position" puts you right back to the way we've done it for the last 100 years, look out the windscreen! And since in VFR we do have the possibility of encountering the J3Cub, that still not a bad idea.
Paul 5r4
Well Known Member
Good morning all. I spoke with Scott Edwards from Dallas Avionics a few minutes ago. He stated they are working on the fix for the EXP units. It will more than likely be a two pronged approach.... first a software upgrade, (SIL to 0.... also the possibility of making the SIL end-user selectable. I don't understand that because the AD states it must be set to 0), and then a hardware upgrade down the road. He didn't want to speculate about cost at this time. He added that the communication letters on the Navworx site should be updated by the end of this week. He said navworx is very committed to taking care of all these issues with their customers. Hopefully things start happening soon and then as far as compliance we'll know exactly what we're facing.
roadrunner20
Well Known Member
In all the flying I have done with this system in 1 1/2 years, my traffic alerts have always been spot on. In most cases, I did not immediately see the traffic out the window, but knowing where to look, it was spot on. I continue, box or no box, to scan for AC regardless of what it reports.
It will be safer for the airlines, because you will not be allowed to fly in "their" airspace (for the most part). Don't be fooled; ADSB is all about saving the FAA money and keeping the airlines safe from GA. Any concern for GA is a distant second.
DennisRhodes
Well Known Member
David , I think you may be correct, in the thing to do right now is nothing, But I think I will go the second step and continue to use my 600 EXP as it is until Dec 31 2017 and ask for a test report EACH time i fly just to be sure it doesn't lose its "integrity" . All the limits in accuracy are easy to read off the reports. And unless there's some breakthru from Navworx at that time which I don't expect, I'll throw it in the trash and buy again from another supplier. Maybe by that time the dust will be settled and the FAA can decide what it is they want. Looks like the international market place is keying in on ADSB and actually are making some pretty good " certified" products.
Complying with AD via AFM Revisions
In reading the AD if I were making a log book entry stating that i was complying with the AD per Para. e(1)ii in an experimental aircraft how could I log that I complied IAW the AD per para. e(1)ii by Revising the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?USING THE ADS-B SYSTEM IS PROHIBITED.? WHEN I DO NOT HAVE AN AFM OR POH? or para e(1)iv which states Revise the Limitations section of the AFMS by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?OPERATION USING THE INTERNAL POSITION SOURCE IS PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL POSITION SOURCE IS REQUIRED.? WHEN I DO NOT HAVE AN AFM OR POH?
I have reviewed FAR 21.5, 21.191, 21.193, 91.319, 91.9, AC 60-6B, AC20-27G and my aircraft's Operating Limitations no where is it required to have an Aircraft Flight Manual (AFM) or Pilot Operating Handbook (POH). How is it possible to comply with the two above methods for AD compliance if I have no AFM or POH to enter the required statements into and am not required to have an AFM or POH?
Definition:
Airplane Flight Manual (AFM). An FAA-approved document that contains information (operating limitations, operating procedures, performance information, etc.) necessary to operate the airplane at the level of safety established by the airplane?s certification basis.
Supplement. Information that supersedes or is in addition to the basic AFM
resulting from the issuance of a supplemental type certificate (STC), or from approved changes to AFM limitations, procedures, or performance information without an STC.
Terminology:
Airplane Flight Manual (AFM): The AFM is a document developed by the airplane manufacturer and approved by the Federal Aviation Administration (FAA) It is specific to a particular make and model airplane by serial number and it contains operating procedures and limitations which meet the requirements of FAR 21.5
Pilot Operating Handbook (POH): The POH is a document developed by the airplane manufacturer and contains the FAA approved Airplane Flight Manual (AFM) information The term "POH" came into existence in the mid-1970s as a result of AOPA's and GAMA's efforts to standardize and expand information contained in the owner's manuals or information manuals of the day
Airplane Owner/Pilot Information Manual (PIM): The PIM is a document developed by the airplane manufacturer containing general information about the make and model of an airplane The airplane owner?s manual is not FAA-approved and is not specific to a particular serial numbered airplane
This manual is not kept current, and therefore cannot be substituted for the AFM/POH It is often used as a way to learn and review aircraft information without removing legal information from the aircraft
(d) Compliance
You are responsible for performing each action required by this
AD within the specified compliance time unless it has already been
accomplished prior to that time.
(e) Required Actions
(1) Within 6 months, comply with either paragraph (e)(1)(i),
(ii), (iii), or (iv) of this AD
:
(i) Remove the ADS
-B unit.
(ii) Disable and prohibit use of the ADS
-B unit as follows:
(A) Pull and secure the circuit breaker and disconnect the internal GPS antenna connector from the ADS-B unit and secure.
(B) Install a placard in view of the pilot that states ?USING THE ADS
-B SYSTEM IS PROHIBITED.?
(C) Revise the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-
and-ink changes to add the following:
?USING THE ADS-B SYSTEM IS PROHIBITED.?
(iii) Revise the software so the ADS-B unit broadcasts a SIL of 0.
(iv) Couple the ADS-B unit with an approved external GPS as
follows:
(A) Interface the ADS-B unit with an Accord NexNav mini LRU GPS
Receiver P/N 21000.
(B) Revise the Limitations section of the AFMS by inserting a
copy of this AD or by making pen-and-ink changes to add the
following: ?
OPERATION USING THE INTERNAL POSITION SOURCE IS
PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL
POSITION SOURCE IS REQUIRED.?
In reading the AD if I were making a log book entry stating that i was complying with the AD per Para. e(1)ii in an experimental aircraft how could I log that I complied IAW the AD per para. e(1)ii by Revising the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?USING THE ADS-B SYSTEM IS PROHIBITED.? WHEN I DO NOT HAVE AN AFM OR POH? or para e(1)iv which states Revise the Limitations section of the AFMS by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?OPERATION USING THE INTERNAL POSITION SOURCE IS PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL POSITION SOURCE IS REQUIRED.? WHEN I DO NOT HAVE AN AFM OR POH?
I have reviewed FAR 21.5, 21.191, 21.193, 91.319, 91.9, AC 60-6B, AC20-27G and my aircraft's Operating Limitations no where is it required to have an Aircraft Flight Manual (AFM) or Pilot Operating Handbook (POH). How is it possible to comply with the two above methods for AD compliance if I have no AFM or POH to enter the required statements into and am not required to have an AFM or POH?
Definition:
Airplane Flight Manual (AFM). An FAA-approved document that contains information (operating limitations, operating procedures, performance information, etc.) necessary to operate the airplane at the level of safety established by the airplane?s certification basis.
Supplement. Information that supersedes or is in addition to the basic AFM
resulting from the issuance of a supplemental type certificate (STC), or from approved changes to AFM limitations, procedures, or performance information without an STC.
Terminology:
Airplane Flight Manual (AFM): The AFM is a document developed by the airplane manufacturer and approved by the Federal Aviation Administration (FAA) It is specific to a particular make and model airplane by serial number and it contains operating procedures and limitations which meet the requirements of FAR 21.5
Pilot Operating Handbook (POH): The POH is a document developed by the airplane manufacturer and contains the FAA approved Airplane Flight Manual (AFM) information The term "POH" came into existence in the mid-1970s as a result of AOPA's and GAMA's efforts to standardize and expand information contained in the owner's manuals or information manuals of the day
Airplane Owner/Pilot Information Manual (PIM): The PIM is a document developed by the airplane manufacturer containing general information about the make and model of an airplane The airplane owner?s manual is not FAA-approved and is not specific to a particular serial numbered airplane
This manual is not kept current, and therefore cannot be substituted for the AFM/POH It is often used as a way to learn and review aircraft information without removing legal information from the aircraft
(d) Compliance
You are responsible for performing each action required by this
AD within the specified compliance time unless it has already been
accomplished prior to that time.
(e) Required Actions
(1) Within 6 months, comply with either paragraph (e)(1)(i),
(ii), (iii), or (iv) of this AD
:
(i) Remove the ADS
-B unit.
(ii) Disable and prohibit use of the ADS
-B unit as follows:
(A) Pull and secure the circuit breaker and disconnect the internal GPS antenna connector from the ADS-B unit and secure.
(B) Install a placard in view of the pilot that states ?USING THE ADS
-B SYSTEM IS PROHIBITED.?
(C) Revise the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-
and-ink changes to add the following:
?USING THE ADS-B SYSTEM IS PROHIBITED.?
(iii) Revise the software so the ADS-B unit broadcasts a SIL of 0.
(iv) Couple the ADS-B unit with an approved external GPS as
follows:
(A) Interface the ADS-B unit with an Accord NexNav mini LRU GPS
Receiver P/N 21000.
(B) Revise the Limitations section of the AFMS by inserting a
copy of this AD or by making pen-and-ink changes to add the
following: ?
OPERATION USING THE INTERNAL POSITION SOURCE IS
PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL
POSITION SOURCE IS REQUIRED.?
Regarding the no AFMS concern, the AD provides the option of contacting the FAA and asking for an alternate means of compliance. Standard aircraft are not required to have the operating limitations that are attached to our EAB airworthiness certificates. Maybe propose in an AMOC that a copy of the AD be attached to your operating limitations instead of an AFMS change? A quick call to the FAA can't hurt.
(f) Alternative Methods of Compliance (AMOCs)
(1) The Manager, Fort Worth Aircraft Certification Office, FAA, may approve AMOCs for this AD. Send your proposal to: Kyle Cobble, Aviation Safety Engineer, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, FAA, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5172, email [email protected]; or Michael Heusser, Program Manager, Continued Operational Safety Branch, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5038, email [email protected]
(f) Alternative Methods of Compliance (AMOCs)
(1) The Manager, Fort Worth Aircraft Certification Office, FAA, may approve AMOCs for this AD. Send your proposal to: Kyle Cobble, Aviation Safety Engineer, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, FAA, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5172, email [email protected]; or Michael Heusser, Program Manager, Continued Operational Safety Branch, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5038, email [email protected]
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rleffler
Well Known Member
Here's the response I just received from the FAA concerning the AMOC and any future hardware/software upgrades from Navworx.
Mr. Leffler,
First, let me address how to apply for the AMOC. Please reference Advisory Circular (AC) 39-10. You can find this on the Regulatory and Guidance Library online. Go to http://rgl.faa.gov. On the right, select Advisory Circulars, and then you can do a search for 39-10.
Section 3-2 details the information that should be included in the AMOC. The AMOC should go through your Flight Standards Principal Inspector, according to paragraph 3-4. So, I would think you could e-mail the AMOC proposal to your PI, and he could forward it on to us, but that’s something you should ask him. Alternatively, if you wanted to present your proposal to the PI, he could give you an endorsement letter stating that he has reviewed the proposal and has no further comments. You could then e-mail the proposal to us (the ACO) and include the PI's endorsement letter. We ask that you submit an ADS-B performance report that has been performed since the AD was published (June 7, 2017). It would be ok to e-mail and electronic version to us at the ACO for inclusion with the AMOC. You should also list the data that was used for the installation, such as the NavWorx installation manual and version number. I believe we have enough experience and data with the GTN650 that it will allow us to issue an AMOC.
We are aware that some of the owners may not have a working relationship with a PI, especially those with experimental aircraft. If that is the case, let me know, as we may have to come up with a work around or provide further guidance on how to submit the proposal.
The other question on NavWorx upgrades is a little nuanced. If the NavWorx upgrade is to set SIL back to 0, then you can check with our office to see if that particular software version has been approved. If so, you could install that version, since the AD allows such a change to be installed if it becomes available. If the upgrade is to set the SIL to some value other than 0, then you may still have to apply for an AMOC for that version. When that time comes, you can call me or Mike Heusser for guidance.
Kyle Cobble
Fort Worth ACO
817-222-5172
Bill has insisted that external GPS units, such as the GNS430 and/or the GTN650 were approved GPS sources. The AD states that isn't the case. It appears that the burden is on us to file an AMOC for each of our certified GPS, but we may have to for each of the proposed Navworx upgrades. It appears that while Bill is offering what he thinks in an acceptable upgrade path to resolve this current situation, the FAA may have another opinion.
I have a good relationship with the local FSDO office, but I don't know how onerous is the AMOC process or is it something that an individual can accomplish. I guess it's time to get started. The link to the AMOC is: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/e5053168f0cc2c1f862580300058f80f/$FILE/39-10.pdf
Update: I just read the AMOC instructions. It seems like a more bureaucratic process than a technical one, especially with well known certified GPS sources. It's going to be a couple weeks before I can start working on this, since I'm in the midst of a panel upgrade that I need to get completed first. It seems to me that we may want to organize and request a Global AMOC. The requirements seems to be that you need to add make/model and serial number of each aircraft to be included. I suspect that there needs to be an AMOC filed for each certified GPS. The question then becomes how to we handle the coordination and track all the aircraft that needs to be included in the Global AMOC. Thoughts?
Update 2:
I have been out for a few days.
I will get back with you regarding the Garmin GTN650 nav source.
Thanks,
Michael Heusser
Program Manager
Fort Worth Aircraft Certification Office
Phone: 817-222-5038
Mr. Leffler,
First, let me address how to apply for the AMOC. Please reference Advisory Circular (AC) 39-10. You can find this on the Regulatory and Guidance Library online. Go to http://rgl.faa.gov. On the right, select Advisory Circulars, and then you can do a search for 39-10.
Section 3-2 details the information that should be included in the AMOC. The AMOC should go through your Flight Standards Principal Inspector, according to paragraph 3-4. So, I would think you could e-mail the AMOC proposal to your PI, and he could forward it on to us, but that’s something you should ask him. Alternatively, if you wanted to present your proposal to the PI, he could give you an endorsement letter stating that he has reviewed the proposal and has no further comments. You could then e-mail the proposal to us (the ACO) and include the PI's endorsement letter. We ask that you submit an ADS-B performance report that has been performed since the AD was published (June 7, 2017). It would be ok to e-mail and electronic version to us at the ACO for inclusion with the AMOC. You should also list the data that was used for the installation, such as the NavWorx installation manual and version number. I believe we have enough experience and data with the GTN650 that it will allow us to issue an AMOC.
We are aware that some of the owners may not have a working relationship with a PI, especially those with experimental aircraft. If that is the case, let me know, as we may have to come up with a work around or provide further guidance on how to submit the proposal.
The other question on NavWorx upgrades is a little nuanced. If the NavWorx upgrade is to set SIL back to 0, then you can check with our office to see if that particular software version has been approved. If so, you could install that version, since the AD allows such a change to be installed if it becomes available. If the upgrade is to set the SIL to some value other than 0, then you may still have to apply for an AMOC for that version. When that time comes, you can call me or Mike Heusser for guidance.
Kyle Cobble
Fort Worth ACO
817-222-5172
Bill has insisted that external GPS units, such as the GNS430 and/or the GTN650 were approved GPS sources. The AD states that isn't the case. It appears that the burden is on us to file an AMOC for each of our certified GPS, but we may have to for each of the proposed Navworx upgrades. It appears that while Bill is offering what he thinks in an acceptable upgrade path to resolve this current situation, the FAA may have another opinion.
I have a good relationship with the local FSDO office, but I don't know how onerous is the AMOC process or is it something that an individual can accomplish. I guess it's time to get started. The link to the AMOC is: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/e5053168f0cc2c1f862580300058f80f/$FILE/39-10.pdf
Update: I just read the AMOC instructions. It seems like a more bureaucratic process than a technical one, especially with well known certified GPS sources. It's going to be a couple weeks before I can start working on this, since I'm in the midst of a panel upgrade that I need to get completed first. It seems to me that we may want to organize and request a Global AMOC. The requirements seems to be that you need to add make/model and serial number of each aircraft to be included. I suspect that there needs to be an AMOC filed for each certified GPS. The question then becomes how to we handle the coordination and track all the aircraft that needs to be included in the Global AMOC. Thoughts?
Update 2:
I have been out for a few days.
I will get back with you regarding the Garmin GTN650 nav source.
Thanks,
Michael Heusser
Program Manager
Fort Worth Aircraft Certification Office
Phone: 817-222-5038
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DennisRhodes
Well Known Member
I didnt really think the FAA could make this more complicated than the fiascos witnessed prior to the AD final rule. But looks like they have done it again. Talk about creating jobs and legal paperwork, they are the best. And i thought it was only the IRS that needed reorganized. Maybe MAGA will address some of this. We seems to pay for it anyway.
Please leave a text number where i can send a pic of my 600 EXP in a trash can. Thats about all the paperwork im going to do.
Please leave a text number where i can send a pic of my 600 EXP in a trash can. Thats about all the paperwork im going to do.
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Indycanard
Member
I sent an email to the Ft Worth FAA ACO in regards to this AD this morning. I specifically asked if an alternate "non-TSO" GPS source solution would be entertained by the FAA in an AMOC request, and if so, what data would be required. I specifically mentioned the GRT Safe Fly 2020 (http://www.grtavionics.com/safeflygps.html
For my specific NavWorx box (very early 200-0012), it would be more expensive to have NavWorx upgrade the GPS vs. going with another mfg external GPS (such as GRT).
In lieu of an email response, Mike Heusser called me and we spoke for a few minutes. He sounded VERY agreeable to consider AMOCs utilizing other than TSO certified GPS sources.
Further, we discussed a Global AMOC approach approving certain combinations of GPS sources and the three NavWorx box versions. Mike indicated the ideal solution would be to have a single Global AMOC approved allowing certain GPS solutions with each of the three NavWorx boxes in question. The data needed would be each combination GPS and NavWorx box would be flight tested and a performance report generated. The GPS source would also have to be acceptable, perhaps with data from the Mfg, which the FAA probably already has.
Mike will be working thru details in the near term, and his thought would be to work with the alphabet groups (EAA/AOPA) to get the combinations tested with each proposed solution installed to make sure the systems talk to each other and perform acceptably. Once done, a Global AMOC would be approved that would require no individual action except to file a copy with your aircraft documents. Mike promised an email response to me once more details are know that can be shared.
Bottom line, don't throw those NavWorks boxes away yet.
Henry
Seattle WA
N85TT
For my specific NavWorx box (very early 200-0012), it would be more expensive to have NavWorx upgrade the GPS vs. going with another mfg external GPS (such as GRT).
In lieu of an email response, Mike Heusser called me and we spoke for a few minutes. He sounded VERY agreeable to consider AMOCs utilizing other than TSO certified GPS sources.
Further, we discussed a Global AMOC approach approving certain combinations of GPS sources and the three NavWorx box versions. Mike indicated the ideal solution would be to have a single Global AMOC approved allowing certain GPS solutions with each of the three NavWorx boxes in question. The data needed would be each combination GPS and NavWorx box would be flight tested and a performance report generated. The GPS source would also have to be acceptable, perhaps with data from the Mfg, which the FAA probably already has.
Mike will be working thru details in the near term, and his thought would be to work with the alphabet groups (EAA/AOPA) to get the combinations tested with each proposed solution installed to make sure the systems talk to each other and perform acceptably. Once done, a Global AMOC would be approved that would require no individual action except to file a copy with your aircraft documents. Mike promised an email response to me once more details are know that can be shared.
Bottom line, don't throw those NavWorks boxes away yet.
Henry
Seattle WA
N85TT
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Indycanard
Member
You are correct. I asked about a non-TSO GPS source such as the GRT source in lieu of the $$$$$ TSO Garmin boxes. I didn't mean non-WAAS.
I will correct the my previous post - Thanks
Indycanard
Member
You may be correct, or at least correct until NavWorx can modify your EXP box to allow external GPS feed (if ever). You may be stuck with the NavWorx internal GPS upgrade solution.
Mike H with the FAA-ACO is aware the EXP doesn't have the capability for external GPS solution.
It should be noted according to Scott with Dallas Avionics (NavWorx support focal), the "FAA-approved external GPS source is the Accord NexNav mini P/N 21000" specifically mentioned in the AD is a no longer used GPS in the NavWorx boxes. As it is, I don't see how an external GPS (even if FAA approved) can be used with the EXP box without a serial port. A new solution is in work by NavWorx
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Tim, the antenna is a dumb device. The offending GPS parts are internal to the EXP. I'll give NavWorx the benefit of the doubt until Oshkosh. If a path forward for the EXP is announced at that time I will follow that path. If it isn't an ironclad solution mine will become a paperweight and I'll turn to the GRT/uAvonics solution and their proven track record of actual real customer service. If you want more details on the latter comment please contact me by PM or email.
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[email protected]
I'm New Here
Talked to Scott Edwards from Dallas Avionlcs today. He believes NavWorx will put out a software fix plus some sort of approval from the FAA blessing several alternate position sources. I was inquiring about my setup with the Ads600-B and my GNS430W and whether I would need to submit an AMOC. He said I would not and the NavWorx release would solve
our problems.
I await.
Bob Ashey
RV10 500 hours
our problems.
I await.
Bob Ashey
RV10 500 hours
DavidBunin
Active Member
I've been trying to read the tea leaves on this one. As I understand it, a new software release from NavWorx alone isn't enough. Somebody will need to apply for AMOC coverage, unless the FAA plans to revise the AD (which they almost never do, unless it is to expand effectivity).
That doesn't mean that everybody needs to apply for AMOC coverage, but whoever does it first should ask for a "Global AMOC". That way, the AMOC can be offered to anybody flying that configuration; for example the 200-0012 + GNS430W.
If the FAA is smart, they will grant that Global AMOC to the first applicant they get for each configuration. (Even if the applicant doesn't specifically ask for Global approval.)
I don't know if the FAA can group configurations onto a single AMOC. If not, then we're looking at a separate Global AMOC for each of the following:
200-0012 + GNS480
200-0013 + GNS480
200-0012 + GNS430W
200-0013 + GNS430W
200-0012 + GTN650
200-0013 + GTN650
200-0012 + IFD540
200-0013 + IFD540
This assumes that the FAA accepts the GNS530W as the same GPS as the GNS430W, and so on for the GTN750/650 and the IFD440/540. If not, then double that list.
The ADS600-EXP (part number 200-8013) does not have the capacity to be slaved to an external GPS, so there will have to be some kind of software solution there. I haven't tried asking detailed questions yet about that.
David
[email protected]
I'm New Here
I'm hoping that person is NavWorx.
Bob
Bob
Indycanard
Member
As I stated above, The FAA is hoping to work with AOPA/EAA to test out many combinations of GPS sources with the NavWorx ADS600B boxes. Maybe the EAA and or AOPA would formally request the Global AMOCs on behalf of the individuals. The FAA doesn't want 600+ AMOC requests as that would overwhelm them. Also, they are not bent on only the TSO'd GPS sources such as the Garmins, but also the experimental (meets the TSO specs) such as the GRT Safe Fly 2020 and other vendors.
In the short term, it is best to let the dust settle and allow Navworx get to work. They may also be involved in AMOC solutions with other GPS solutions.
DavidBunin
Active Member
That would be ideal for us, but NavWorx doesn't own a fleet of aircraft with one of each piece of equipment installed.
They do own units for bench testing in the lab, where it actually is quite easy to induce/simulate the kinds of problems that the FAA claims to be worried about (failure of a satellite signal). But if they did take the time to witness those tests, they would then see that there was no issue in the first place.
Since the FAA has shown no interest in lab tests, this is going to "take a village" instead.
[email protected]
I'm New Here
Ralph, good work. Hope you'll share if you're approved.
Bob
Bob
Thanks, sounds like that'll help, but (from Kyle Cobble, FAA):
A global AMOC for the GNS430W would not automatically extend to the 400W. We will need to receive data and issue an AMOC for each GPS part number. However, if there is a global AMOC for the GNS430W, I would anticipate that it would make it quicker and easier to approve an AMOC for someone who proposes the GPS 400W.
So someone will have to go through the process for each model.As for waiting on NavWorx as Indycanard suggests -- after so many missteps and misstatements (the latest being, that 430W et-al would be approved as alternate position sources in the forthcoming AD), the needle on my "benefit of the doubt" meter has pegged. I believe that to the extent possible, we need to take control of the process ourselves. Unfortunately we'll still need the promised SW update to report the approved position source -- I think?
DavidBunin
Active Member
It's worse than that. If Kyle really sticks to that strict interpretation of "each GPS part number" then the problem explodes, because Garmin has made about twenty different part numbers of the GNS units.
David Bunin
Here's his answer to that:
I expect that we will be able to give an AMOC for general part numbers, such as GNS 430W, without having to go down to revision levels. The only exception might be the GNS 480, which I believe was only compliant with 91.227 after a specific revision level.
Generally, yes, it would be easier to wait for a global AMOC. That being said, some of the entities may be looking for people who would allow their airplanes to be used as the basis for the AMOC. If you are interested, we may be able to put you in contact with them.
As I mentioned previously, I'm not content any longer to sit and wait for things to happen, plus my GPS-400W won't be as likely to get approval as soon as others e.g. the 430W. So I will be taking him up on that offer.Generally, yes, it would be easier to wait for a global AMOC. That being said, some of the entities may be looking for people who would allow their airplanes to be used as the basis for the AMOC. If you are interested, we may be able to put you in contact with them.
