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Confused Garmin G3X demo in French (enabling uncertified aircraft to fly IFR)

The fact that sometimes approved systems also misbehave (can you say MCAS on the B737 MAX) is no reason to abolish certification altogether.

This is completely different, and has little to do with certification. MCAS is not a standard component or system, like for instance an altimeter or some avionics that must adhere to some production, performance and design standard. There is no standard for the MCAS itself to be certified after for a third party, as I understand it. It’s the final behaviour of the aircraft that must behave according to a standard.

The MCAS problem is more this kind of problem IMO, only the experts at Boeing obviously also lacked expert knowledge.



The elephant is the circulation
ENVA ENOP ENMO, Norway

I’m all with Malibuflyer here. The fact that sometimes approved systems also misbehave (can you say MCAS on the B737 MAX) is no reason to abolish certification altogether.

Where I do think that things have gone out of hand is with installation certifications. It is much simpler to show that a particular installation is safe than to show that the boxes themselves are.

ESKC (Uppsala/Sundbro), Sweden

@Malibuflyer wrote
“We have seen radios that cause massive interruptions in the whole spectrum – but just when tuned to one specific frequency. AIs that start to tilt in level flight over time – but only after 5-10 minutes in continuous descent, etc. How would you “prove” that none of this happens by a simple test flight?”
Yes we have seen all these things in expensive TSO’d certified avionics with ecpensive STC’s to be used in certified aircraft. It might be that the uncertified equipment, with much less regulatory oversight and tested by the owner on the type of mission s/he wishes to undertake would have a better track record than much of the certified equipment in IFR use today.

“And why is private ops so different from non private ops? Are the people you hit on the ground because you crash 3 miles short of the runway less dead if the ops have been private?”
A Jodel 1050 or a MCR 01 is likely going to do far less damage to people on the ground than your PA46 if it crashes. In fact the whole “raison d’ être” behind the ULM maximum weight restrictions in France is based on an algebraic calculation of the risk of killing someone on the ground if you were to crash on them.

 

France

Mooney_Driver wrote:

In basic terms you could approve any installation by conducting a flight test and seeing if it does what it’s supposed to do for private ops plus run a simple avionic check (externally) on the conventional avionics. As long as this works out within proper tolerances in flight path and indication, you may use it for IFR.

Sorry but that doesn’t work: Just that a box seems to indicate not complete nonsense on one flight in one situation doesn’t tell you anything! You can’t “prove” anything with this (beyond that it worked in this specific flight). Yes, certification is also a lot of paperwork – but the car cost driver of certification is not any kind of “government procedure” but simply the fact that you need to test the equipment in many different uses in many different situations. How can you “prove” after one test flight, that the equipment delivers the relevant information w/o errors?

We have seen radios that cause massive interruptions in the whole spectrum – but just when tuned to one specific frequency. AIs that start to tilt in level flight over time – but only after 5-10 minutes in continuous descent, etc. How would you “prove” that none of this happens by a simple test flight?

And why is private ops so different from non private ops? Are the people you hit on the ground because you crash 3 miles short of the runway less dead if the ops have been private?

Germany

Malibuflyer wrote:

Don’t understand your point!
Isn’t your “prove in flight test” exactly what we call “certification”?

Certification goes way beyond this.

In basic terms you could approve any installation by conducting a flight test and seeing if it does what it’s supposed to do for private ops plus run a simple avionic check (externally) on the conventional avionics. As long as this works out within proper tolerances in flight path and indication, you may use it for IFR.

Certification means each box has to pass the whole government procedure of several years plus needs to be fixed panel mounted plus plus plus.

Eg, any sort of PFD which can display all necessary data combined with a 8.33 com/nav/gs receiver and a say GPS696 or similar which has data connections to feed an AP and the PFD would be legal to use if it can be proven in a flight and ground test that the equipment delivers the required performance. Keeping within approach tolerances e.t.c. is the Pilots problem anyway, all the equipment has to do is to assure he gets the relevant information.

Looking at a normal installation which requires tons of paperwork and expensive certified boxes which sometimes can’t even do what the uncertified stuff does, for private ops this may well be a way to go. Possibly even further, if you abolish the need for STC’s e.t.c. in favour of a simple functionality check also for other things.

LSZH(work) LSZF (GA base), Switzerland

Peter wrote:

Certification in avionics is a wide range of things. Most of it (TSO) is environmental compliance. Some of it is software design procedures.

It all comes down to “prove it works”. Obviously even w/o certification you don’t want to have your new box interfere with radio communication or even mess ups the entire electrical system of the plane.
And the “software design procedure” requirements (or the entire concept of design or manufacturing authority) is actually to reduce certification burden rather than to increase it: The idea is than instead of actually demonstrating the device works in every situation that might occur in some point in time it is enough to demonstrate that it has been designed thoughtfully and thoroughly. That is a huge advantage.

I was more commenting on the idea that you can “prove in flight test” instead of certification. Often if someone says “prove in flight test” they really mean nothing close to a prove but rather a “I turned it on once and it happen to show something that did not look completely wrong”.

We must not forget, that IFR equipment is not only used for way finding or approach (so only killing ourselfs and perhaps few people on the ground if this ground comes close to us quite unexpected in case of a malfunction) but also for separation where we might kill people in other planes as well.

Germany

the alps are mainly a Swiss problem (and some Austrian and French) ;-)

I’d add that the Alps are quite a big “Italian problem” too I have certainly spent rather more time in the “Italian problem” in recent years…

The reason Germans travel internationally a lot is because many of them (a) are ok with using English and (b) have lots of money. Germans travel a lot over the Alps because it is just down the road, and they can do it in the usual “club” planes. Quite a few do Mali Losinj as a day trip, for example; I’ve met many down there. For Swedish pilots, ELP is a non-issue (they are mostly very good) but they have a long way to fly. For Brits, it is equally a long way to cross the Alps out of the UK; you need something like a TB20/SR22/etc.

What drives the broad travel patterns is really mostly quite simple.

Second order factors are things like IR adoption which also needs good ELP. In France, historically, you could get an IR in French only but that’s no longer possible, so together with the French cultural preference to holiday in France, there you go. Conversely Germany has a high IR adoption for various reasons – especially the JAA/EASA IR, which Brits avoided like the black death, going mostly FAA/N-reg – and that enables international travel.

I think, referring to the OP, that France benefits less from an IR / IFR capability than most other countries in Europe. It has

  • good wx (well, the bottom 2/3)
  • good airspace structure for VFR (below FL120, anyway)
  • super-relaxed ATC services for VFR
  • good scenery
  • lots of airfields (most of which are VFR-only)

Pic from the EuroGA airport database map:

Administrator
Shoreham EGKA, United Kingdom

Jacko wrote:

Agreed, and this seems predominantly to be a Swiss and German problem

Yes – the alps are mainly a Swiss problem (and some Austrian and French) ;-)

And yes: Germans tend to fly more often through this “Swiss problem” to get to the Mediterranean than UK or Swedish pilots. Might be due to regulation – or simply due to geographic distances …

Germany

Certification in avionics is a wide range of things. Most of it (TSO) is environmental compliance. Some of it is software design procedures.

Administrator
Shoreham EGKA, United Kingdom

Mooney_Driver wrote:

but you can not legally couple a fully RNAV capable uncertified device to any autopilot even for single axis ops (e.g. LNAV with VNAV being flown manually) and then prove in flight test, that the device performes to specification.

Don’t understand your point!
Isn’t your “prove in flight test” exactly what we call “certification”?
Therefore what is the difference in your argument between a certified device and a device that has “proven” it performs to specification?

Germany
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