Going Experimental?

[WWFeldman]

That only really applies if the equipment is required to meet a TSO (not necessarily be TSO'd). So unless it's a transponder or GPS navigator, it doesn't need to meet, or be, any TSO.

Gotcha. I searched this site for more info, and I found the Jim Weir someone else mentioned. Here's the thread he was on https://www.pilotsofamerica.com/community/threads/non-tso-for-certified-aircraft.104981/
and he said ... There IS NO such thing as experimental avionics. And for part 91, the only things that have to MEET (not BE) TSO'd are the transponder and altitude encoder (and ADSB-Out). MEET, not BE.

 

[PaulMillner]

called 'conditional inspection' instead of an 'annual' when its an EAB

I think you mean condition inspection? There's nothing conditional about it...

Paul

 

[Bell206]

Why then does Garmin go to the expense of certifying the G3 for the 172?

I stated the reasons above but perhaps a different tack. We’re dealing with different rules and requirements.

For a vendor to produce an article that may be installed on, sold to, or marketed for a type certificated aircraft they must produce that article under an FAA design/production approval. Reference 21.9(a) and 3.5(c). Full stop. This is the reason Garmin and others certify their parts.

However, there is no similar requirement for non TC’d aircraft like E/AB so these same vendors offer a non-certified version, usually with more functions and capabilities as 21.9(a) is no longer applicable. But, 3.5 (c) still is applicable so most vendors label these non-cert versions as “experimental” or something similar. Full stop.

Why would anyone buy it vs the "experimental" version?

In most cases it’s because a lot of people do not understand how the aircraft alteration process works under Part 43. Now in some cases when the use of approved data is required, for example, for a major alteration or work performed under an STC, there usually is a requirement to use the certified version of the article and is spelled out in that data. So no joy.

However, outside of that type of data requirement there is no part certification required for most aircraft alterations. So just like there is a Part 43 alteration process to install a non-certified Cobra CB radio, or Uniden Marine radio, or most any other non-certified article out there in any aircraft, that same Part 43 alteration process can be used to install a non-certified version of a Garmin G3 in a TC’d aircraft.

I own a 1956 172, I could add a non certified Dynon Panel to it as long as it passed the TSO specs?

You’re confusing topics: alteration vs design/production approval. Are you asking if you can alter your aircraft with a Dynon Panel? I think the key here is if that alteration is considered a major or minor alteration. But without more info on what you consider a “dynon panel” I can’t offer more.

the only equipment that must be TSO'd on part 91 aircraft.

Not quite. Items only need to meet TSO performance requirements where noted in 91. You need to get to Part 135 to see an actual TSO requirement.

 

[donjohnston]

Not quite. Items only need to meet TSO performance requirements where noted in 91. You need to get to Part 135 to see an actual TSO requirement.

You are inferred that my used of "TSO'd" means manufactured.

What I meant was that it met TSO spec's. But to be fair, I don't think there's any difference in the world that part 91 airplanes live in.

Which begs the question: How does the typical owner or even A&P validate that a transponder or GPS meets the TSO performance requirements?

 

[Dana]

I think you mean condition inspection? There's nothing conditional about it...

You are correct, but I've seen it called "conditional inspection" even in some FAA documents.

How does the typical owner or even A&P validate that a transponder or GPS meets the TSO performance requirements?

Paperwork provided by the manufacturer, and/or transponder check once installed.

My understanding, somebody please correct me if I'm wrong, is that you need TSO'd devices to replace existing components originally installed in the aircraft; for example, a glass panel that completely replaces the airspeed indicator and altimeter would have to be TSO'd, but one installed as a secondary display for VFR flight would not need to be TSO'd. But devices that could affect other aircraft (devices that transmit your position, i.e. transponder and GPS feeding ADS-B out) must meet a higher standard.

 

[Bell206]

How does the typical owner or even A&P validate that a transponder or GPS meets the TSO performance requirements?

From a paperwork standpoint TSO performance can be verified by the TSO number on the unit data tag, OEMs reference stating the unit meets the TSO, OEMs technical specifications sheet indicating meets TSO, or compare unit tech sheet to TSO tech sheet. Operationally for a transponder, each 91.413 check also verifies the TSO performance requirement.

 

[Bell206]

is that you need TSO'd devices to replace existing components originally installed in the aircraft;

It depends on item and how replaced, but in general, no. For example, the Part 91 "meet TSO performance" still applies whether you replace units or not. Now in some cases like ELTs, if it is a new installation the unit must meet a newer TSO performance vs the older one if different. Also keep in mind a TSO is only a design/production approval and not an installation approval which falls to the installer to determine.

for example, a glass panel that completely replaces the airspeed indicator and altimeter would have to be TSO'd,

More than likely in this case it was a matter of how those instruments were replaced. Since they are primary instruments my guess it was done as a STC or major alteration which as part of the approval process may require TSOA instruments. Or, in the case of a STC, an STC is only a design approval which requires the holders to use a TSOA or PMA as the production approval. So there are various reasons why TSOA cert equipment is used or not.

 

[Cykoguy]

I'm the OP. Thanks for all the comments. What I want to do is to be able to install the great experimental avionics available. AoA's for example. Even the Garmin G5 Exp is something like $1000 cheaper than the certified G5. And they are the same. I want to put in my own designed LED lighting and a lot of other electronics/modifications. Strictly VFR. I would want to fly weekly. I think I could qualify for Research and Development Experimental. I guess that would be up to my local FSDO?

My plane, a Musketeer Sport is a great plane. Maybe I could get $30k for it. Where can I find an experimental anywhere even close that has equivalent capability? I'm 73 YO, too late for an A&P.

Research and Development is going to require you to actually perform said research and development and not just be trying to get around the rules. Trying to put this the nicest way but there is no chance they let you do this and I would be afraid of the can of worms you would be opening with the FSDO. There is light on the horizon for more owner maintenance and whatnot included in MOSAIC but that is still at minimum 2-3 years off.

 

[Spacedoc]

In most cases it’s because a lot of people do not understand how the aircraft alteration process works under Part 43. Now in some cases when the use of approved data is required, for example, for a major alteration or work performed under an STC, there usually is a requirement to use the certified version of the article and is spelled out in that data. So no joy.

However, outside of that type of data requirement there is no part certification required for most aircraft alterations. So just like there is a Part 43 alteration process to install a non-certified Cobra CB radio, or Uniden Marine radio, or most any other non-certified article out there in any aircraft, that same Part 43 alteration process can be used to install a non-certified version of a Garmin G3 in a TC’d aircraft.

Bell, this is how my amateur brain understands the process you're describing above- please correct me if I'm wrong.

If you have a certificated aircraft, and it is one of the models on the Garmin G3X Touch Certified STC, your A&P can install the certified hardware per that STC, reference the STC in the logbook, and you're good.

If you want to install the non-certified G3X Touch, your A&P installs it, but has to fill out a 337 and get it approved by the FSDO. They can't point towards the STC since certified hardware wasn't installed.

Is this correct? If so, this is the wrinkle in the "yeah you can install non-certified avionics". You can, but you need a 337?

 

[hindsight2020]

There is light on the horizon for more owner maintenance and whatnot included in MOSAIC but that is still at minimum 2-3 years off.

Meh, justice delayed-justice denied/ waiting for Godot/ pick your platitude. MOSAIC is going to disappoint a lot of people. LAMA admitted from the jump the main thrust of the lobbying effort is revenue allowance of LSA as it exists. The rest is just astroturfing with what they know the FAA will never allow to pass (owner-mx category, retrofitting fac built 4 seater performance into LSA allowance et al). I learned my lesson from the part 23 re-write nothingburger. Wasted time. EAB is the answer, and it currently exists.

 

[Salty]

Bell, this is how my amateur brain understands the process you're describing above- please correct me if I'm wrong.

If you have a certificated aircraft, and it is one of the models on the Garmin G3X Touch Certified STC, your A&P can install the certified hardware per that STC, reference the STC in the logbook, and you're good.

If you want to install the non-certified G3X Touch, your A&P installs it, but has to fill out a 337 and get it approved by the FSDO. They can't point towards the STC since certified hardware wasn't installed.

Is this correct? If so, this is the wrinkle in the "yeah you can install non-certified avionics". You can, but you need a 337?

You need a 337 with the Stc install also, but no approval is required.

 

[Bell206]

this is how my amateur brain understands the process you're describing above

First, it’s best to determine if what you want to install is considered a simple replacement, minor alteration, or major alteration. Only a major alteration will trigger the 337 requirement in addition require approved data to install.

If you have a certificated aircraft, and it is one of the models on the Garmin G3X Touch Certified STC, your A&P can install the certified hardware per that STC, reference the STC in the logbook, and you're good.

If the G3X cert is considered a major alteration you’re A&P will also need to complete a 337 and have an IA sign it in addition to the logbook entry. The STC provides the approved data requirement. If it is not considered a major alteration then no 337 needed.

If you want to install the non-certified G3X Touch, your A&P installs it, but has to fill out a 337 and get it approved by the FSDO. They can't point towards the STC since certified hardware wasn't installed.

Technically yes, if it is considered a major alteration. But get the 337 approved 1st before install. Keep in mind getting that type of data or request approved at the FSDO level may not be possible and require it to be handled by the ACO. Now you’re at the STC level of approval which is a whole different ball game. So for some complex installs/alterations, while it is possible, it’s usually is not economically feasible. However, if this is not a major alteration then rock on with a logbook entry, but I doubt a G3X is minor alt.

If so, this is the wrinkle in the "yeah you can install non-certified avionics".

The “wrinkle” to install non-certified equipment in a TC aircraft via the alteration process works best when the equipment is not complex and can be done as a minor alteration. Even so have seen people use this method for some complex or odd items with success at the major alt level. However, I doubt you’ll be able to complete the process for the exp G3X at a price point cheaper than what Garmin sells their cert G3X for. Make sense?

 

[Spacedoc]

Thanks for the clarification!

 

[jrollf]

I think you mean condition inspection? There's nothing conditional about it...

Paul

Yes, I miss typed it.

 

[AlphaPilotFlyer]

There’s a lot of mis information about taking certified to non certified. The limitations are well spelled out in nationwide FAA policy, and they are about the same as Amateur built now for your size class 1 plane. My c172 is experimental due to having a V8 engine, and there are many benefits to me, mostly it cost about $18/hr to fly and it out performs original engine by a huge margin. I don’t have any geographic limits or radius restrictions. A buddy is taking his CFI check rides in it next month, and he saved a lot of $ compared to earlier renting same vintage airplane for $130/hr during his training.

converting your plane to exp for merely ability to do your own without A&P sign off won’t work I’m afraid unless you are in Canada. FAA part 43 maintenance requirements/regulations for certified aircraft also pertain to “aircraft previously certified”. So even though your plane would have an exp AC, you would still need to use A&P. However, it would allow you to use non-certified parts and components, such as exp avionics.....you would just need to have an A&P sign off on the install. I installed a TALOS EFIS unit that feeds an IPad mounted on the panel for less than $1k and works great even though it’s experimental. It’s small and has ADSB in as well as pitot static inputs. It has synthetic vision, traffic, weather, flight director, moving map with either sectional or IFR charts, flight routings and more features than the Boeing I fly at work.

The most expensive operating cost item is the engine and there’s really not a whole lot of savings buying the experimental versions of parts or overhaul labor, pluse cost of AVGAS. Also, unless you find a kit for your model, you will likely need to hire a DER and DAR to help with manual and other docs which will cost way more than selling at a loss and buying a finished AB....which would be my suggestion.

there’s a thread dealing with moving to exp which you may wish to reference for more info. The Corsairpower.com and v8seabee.com also have good info. But again, I don’t think converting to exp makes sense for your objective. Canada has owner maintained category which is great for keeping legacy airframes flying... I got calls about selling my c172 from Canadians that want to do just that.

FAA will likely change LSA regulations to allow easier conversion for class 1 legacy airframes which allow more owner maintenance, but there seems to be a lot of pressure from the original manufacturers so expect it will be years before finalized.