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Certified aircraft with uncertified avionics?

This twin comanche has a Dynon Skyview D700 on the center of the panel.

Potentially it is installed as moving map only, or as a full synthetic vision EFIS/HSI with the ADAHRS connected to the Pitot/Static system.

Last Edited by ploucandco at 23 Jan 11:06
Belgium

I don’t know one shop who would accept that installation …

Peter wrote:

Since that G296/496 holder is obviously connected to the aircraft electrical system, what is the procedure there? A separate CB, or alternatively using an existing CB and verifying the appropriate rating?

Sure, you must ensure it meets the certification specification of the aircraft, in this case CS-23. So you will need to use propper wiring, a fuse, make an electrical load analysis, install it with standard hardware etc. etc. So you can’t just screw it in, you must make a design, to show it can be done in good order.

Peter wrote:

What does that actually mean? There is no regulation specifying what equipment is to be used (only carriage is specified). Obviously such a GPS will not confer any BRNAV etc privileges

That you are not allowed to use that piece of equipment, during night or when flying an IMC. You are not allowed to use it at all. This is regulation specifying you can NOT use it. Your view is just the opposite.

It says:

The following standard contains acceptable data:
— FAA Advisory Circular AC 43-13-2B, Chapter 1 and 2.
Additionally, the following applies:
— the design of the equipment installation must take into account crashworthiness, arrangement
and visibility, interferences with other equipment, the canopy jettison (if applicable) and the
emergency exit;
— a data bus/data connectivity between the installed equipment and other equipment which is:
 ETSO authorised (or equivalent), or
 required by TCDS, AFM or POH,
 required by other applicable requirements such as those for operations and airspace, or
 mandated by the respective MEL, if this exist,
is not allowed unless the equipment being installed is explicitly listed by its manufacturer as
compatible equipment to be connected to;
— the equipment is suitable for the environmental conditions to be expected during normal
operation;
— the equipment is not used as primary means of navigation; and
— instructions and tests defined by the equipment manufacturer have to be followed.
4. Limitations
— The system is not to be used in conjunction with night vision systems or in night or IMC
conditions.
— The provided information is used only in an advisory or supplementary manner (no hazard, no
credit basis).
— Any limitations defined by the equipment manufacturer apply

Peter wrote:

I am also curious that such an installation is OK for the initial transfer to a G-reg. It would mean that all kinds of stuff can be accepted which in the past would definitely have to be removed.

Why? This was always possible under EASA a minor change approval, no it became even less hassle with CS-STAN. Though even with CS-STAN you should make a design, to show you have considered all points. Do note this is a GPS situation. I don’t know what you mean of all kinds of stuff, because GPS moving map has this accemption, all other stuff might not have this accemption.

JP-Avionics
EHMZ

ploucandco wrote:

Potentially it is installed as moving map only, or as a full synthetic vision EFIS/HSI with the ADAHRS connected to the Pitot/Static system.

This is a different situation. I find it hard to believe this is legally installed in an EASA aircraft (if it is). Flight instruments are required to be TSO / E-TSO certified, which the Dynon isn’t. With some other TSO’s it is sufficient to meet the TSO or ETSO specifications, without being certified according the TSO or ETSO. This can be done with an alternative mean of compliance.

In this case, even a design organisation wouldn’t be able to issue an approval IMHO.

JP-Avionics
EHMZ

@ploucandco – reports of such installations have appeared sporadically in the USA.

While anything can be done if you keep a low profile I have seen reports of an FSDO approving it as a Field Approval (Major Mod under a 337 + Field Approval docs) and that is astonishing. IMHO it was an oversight by an FAA FSDO inspector, because nobody has AFAIK found any regulatory change supporting this. And I think Jesse says the same thing above w.r.t. EASA-regs.

@jesse – I did a google for the exact phrases and found your text here [ local copy ] on page 19.

This certainly breaks new grounds in aviation regulation especially as it is meaningless because there cannot ever be any way to enforce it. All they could have said is that “the equipment does not confer any rights for equipment carriage compliance for night or IFR flight”. But whoever wrote that reg, IMHO, was a certification person who didn’t know how aviation works.

Administrator
Shoreham EGKA, United Kingdom

I’d like to think that the people writing the document knew exactly what they were writing and why and that they deliberately chose to not get in the way of people having additional tools at their disposal, regardless of placards. Where they wanted to be explicit, they said so, e.g. the limitations of CS-SC001a (comm equipment) explicitly saying that “The equipment installation cannot be used to extend the operational capability of the specific aircraft (e.g. from VFR to IFR operation).” It would hopefully follow that things in EASA are getting better (easier, less expensive, more in tune with reality) for GA.

tmo
EPKP - Kraków, Poland

achimha wrote:

How is this possible? They say the C4 uses non TSO’ed avionics

Correct. This is made possible by the Part 23 rewrite (the EAA has already completed theirs, the FAA is still lagging on it). The new regulation allows non certified avionics to be configured in a Part 23 aircraft as long as the manufacturer designs and builds the aircraft with a given panel defined.

This will mean no one will be allowed to swap out, add to or change the panel without the manufacturer okay. This is similar to how Special Light Sport works except change requests are made via LOA.

In the case for the C4 you will see an all Garmin panel, the non TSOd G3x and the certified GNC 750. You will also see round gauges as backups (hopefully they will change these to be a small glass backup like Cirrus is now providing).

Last Edited by USFlyer at 23 Jan 16:54

I think this is a variation of an EFB mounting. FAA Guidance is provided in AC 20-173.

KUZA, United States

AC 20-173 is here

Some interesting bits in there e.g. it needs its own switch, not just a CB:

This one could be fun…

Administrator
Shoreham EGKA, United Kingdom

The FAA has just released this policy document

Administrator
Shoreham EGKA, United Kingdom
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