Dynon updates our fully certified Transponder, in the field, in your plane as part of a normal SkyView update. As far as we have experienced, it's not a requirement by the FAA that software in a certified device only be updated by a dealer or mechanic, so let's not be too hard on the FAA, OK?
--Ian Jordan
Dynon Avionics
Ahhh, but there is the difference - the 'Dynon' (actually manufactured and certified by Trig in a completely different facility in a completely different country to a completely different TSO/ETSO than a GTN) transponder coupled with the Dynon Skyview has a clearly defined and repeatable process (at least in the FAA's eyes) and is not part of an FAA approved manufacturing spec for an entire installed configuration (Skyview or AFS and that Txpdr)...and has been that way from day one of said configuration.
Also at this time the aforementioned combination can't currently be installed into a certified airplane like the 145/146 boxes discussed in this thread....(of which may or may not find themselves installed into anything from an RV-12 to a Citation jet). The aforementioned boxes also carry a full AML/STC with a clearly defined/approved ICA, of which I'm not aware the Dynon Transponder has been approved with. Dynon is also not the mfgr of that unit in the eyes of the FAA (and as far as I know not a manufacturer a certified 145/146 box), so the processes approved for mfgr of these boxes can and are different across various manufacturers and their certifications. As Paul mentioned the rules/regs are quite a bit more complicated than some may think and as he mentioned are rarely if ever universal (especially betwixt different PMA's, TSO's, products, etc..). If you want a bunch of boring reading, read all of 14CFR21 (and 23).
My point is comparing a product made by someone else to a different (and almost infinitely simpler) TSO, in a different certified facility with a different set of limitations and approved processes is not an accurate comparison. The manufacturing approvals along with continued airworthiness approvals (ICA's) are entirely different across different manufacturers for various specific devices. Each manufacturer has their own set of defined and ultimately approved processes (whether it be PS Engineering, Rockwell, Honeywell, Lycoming, Hartzell, etc..) which they have approved their specific box too, and they never (or very rarely) are identical between companies.
In this case it's likely not entirely either Garmin or the FAA's fault at an individual level, but rather the processes that were setup and certified for that particular box, facility, continued airworthiness, etc... Not unlike most other manufacturers of certified products. In a previous life this is what I did for a living, and I can tell you it's a lot more complicated than simply changing some internal policy - despite the general assumption to the contrary.
Just my 2 cents as usual!
Cheers,
Stein
PS, even if I'm a bit rusty on my 21/23 stuff (like I said, I
USED to do that for a living), I do know Paul is fairly up to date on it...he also used to deal with a set of regulations that make these FAA reg's look like child's play!
but, in the end Ian is partially right, it's not entirely the FAA....I'm saying it's just not entirely Garmin (or any of the other mfgr's with their own certified processes) either.
