Non-TSO for Certified Aircraft

Discussion in 'Avionics and Upgrades' started by Dayron Nunez, Aug 1, 2017.

  1. Dayron Nunez

    Dayron Nunez Filing Flight Plan

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    Hi everyone
    Please first forgive my lack of knowledge in this area, and very new at this, not an aircraft owner, just a private pilot and looking forward to own some time soon hopefully.

    I've been looking at some avionics upgrade stuff on the web and found that all the "same" or similar avionics units have a huge price difference between experimental and certified aircraft which is kind of crazy, although I can imagine why but still annoys me. I did read somewhere that there is a way to go around it installing this non-tso equipment on certified aircraft, or that there is an approvement for that coming in.

    How ever, my question would be, if there is any actual way around this, or if it is possible to install lets say maybe a Garmin G5 or similar Dynon unit on an aircraft that is a VFR only AC and will not be used or certified for any IFR operation, for instance I am looking at a very old very basic VFR only 1957 C172 which doesn't even have an attitude indicator but does have room for it in the panle, could I place a non certified G5 unit there and still use the aircraft as basic VFR?

    Again sorry if my question seems to be too dumb or obvious but I really don't know much about this yet, and I'm trying to learn and understand about this topic.
     
  2. mkosmo

    mkosmo Pattern Altitude PoA Supporter

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    The short answer is no, you can't use experimental avionics in certified aircraft.
     
  3. WannFly

    WannFly En-Route

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    Both units u mentioned are approved for primary replacement in VFR or IFR panel, unless it's running an auto pilot. Even then recently It was announced that G5 HSI will drive AP, some models etc with some restrictions like Attitude information. A whole lot of stuff is changing pretty rapidly in GA and avionics from experimental world are coming in certificated aircraft in lower (relatively speaking ) prices. There are a bunch if threads on almost all of them in this forum under avoinics

    Sent from my SM-G935V using Tapatalk
     
  4. Clip4

    Clip4 En-Route

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    Not all Gizmos require a TSO, but they all require an STC or an FAA field approval for installation in certified aircraft.
     
  5. Witmo

    Witmo Pattern Altitude

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    You're short answer is wrong. The correct answer is "it depends." Lots of certified aircraft are flying around with non-TSOd equipment and many don't need STCs. Talk to your A&P whom you would have do the installation as he's the one that has to sign it off.
     
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  6. mkosmo

    mkosmo Pattern Altitude PoA Supporter

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    There are exceptions to the rule, but it's not easy (or even possible) for most equipment yet. That makes the general rule a no. Sure, some things are easy now (AoA), but you're not getting a non-certified G5 signed off, nor are you getting something like a G3X yet.
     
  7. TigerGene

    TigerGene Pre-takeoff checklist

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    This is how I understand the rules as they apply to avionics.

    The problem in a "nut shell" as I understand it is this; All certified aircraft are eligible to be flown for hire and therefore are expected to have "for hire" or TSO'd equipment installed in an approved manner. Some equipment is manufactured to meet or exceed TSO requirements but has not received TSO approval.

    It is generally accepted that equipment that meets but does not have TSO approval may be installed in certified aircraft IF the installer will sign off on it. I have yet to find an installer in my area that will install such equipment, but they are out there.

    Equipment that is not TSO'd and does not meet the requirements can not generally be instslled in certified aircraft.
     
  8. weirdjim

    weirdjim En-Route

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    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.
     
  9. weirdjim

    weirdjim En-Route

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    You are absolutely and totally incorrect.

    Jim
     
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  10. TigerGene

    TigerGene Pre-takeoff checklist

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    Jim:

    I was shopping for a new Nav radio and came accross the VAL INS 429 all in one, very similar to the Narco Nav 122 currently installed in my Tiger. The Narco Nav 122 is TSOd but the VAL is not (although VAL says it does meet the applicable TSO).

    I could not find any installer in my area that would install the non-TSOd VAL. I was told non-TSOd equipment could not be installed in certified aircraft. Yet, I have seen the VAL installed in other certified aircraft, not to mention the venerable King KX170 installed in thousands of aircraft.

    Have the rules changed or are my local installers mistaken? What gives?

    Would you mind clarifying my understanding of the issue as I previously stated. I thought I had this figured out but apparently I am still in the dark. I too am confused.

    Thanks.
     
    Last edited: Aug 7, 2017
  11. Ravioli

    Ravioli Final Approach

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    What @TigerGene experienced is real. Many shops don't want to deal with stuff that they don't do all the time.

    Some will issue some BS as a reason not to do it, hoping you'll just spend more for the more expensive stuff they do all the time (and overcharge for all the time).

    Instead of asking SGOTI for the rules, ask that installer for the rules. And when the hacking and coughing stops, you can start laughing and buy some drinks with the money you've saved.
     
  12. brcase

    brcase Pattern Altitude

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    My opinion on "what gives".

    The FAA and many installers don't really know the rules or are making up their own rules. Possibly under the guise of liability reasons.
    The FAA may be trying to promote this by making approval of some item more difficult than it should be.
    Installers are not required to install anything, so it is up to them as to what the will install or not.
    Try asking anyone to show you the rule that prevents installation of "X" item before you take their word for it.

    As mentioned there are only a few rules that say you must use equipment that meets a certain TSO.

    Brian
     
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  13. Stewartb

    Stewartb Final Approach

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    To the original question? Garmin G5 and a few Dynon units are available for approved installation in certificated aircraft.

    Your airplane has basic required instrumentation. To remove and replace primary instruments requires approved instruments. Optional equipment like radios? Radios aren't required equipment in CAR 3 vfr airplanes. And so it goes for gps units, etc.

    What's interesting to me is that Dynon went the TSO route for the Skyview system STC but Cubcrafters got approval to install the non-TSOd Garmin G3X Touch w/autopilot in their new X Cub, a Part 23 certificated airplane. Will the Garmin approval ease the way for non-TSO equipment installations? We can only hope!
     
  14. Checkout_my_Six

    Checkout_my_Six Final Approach

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    Stew....the G3X is approved as part of the aircraft TC. That could open the door for other STCs.......but, I bet it will require an STC for an install.
     
  15. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    Glad to see the broad agreement about what is and is not acceptable for a type certificated aircraft.
     
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  16. weirdjim

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    Absolutely not true.

    Jim
     
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  17. weirdjim

    weirdjim En-Route

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    Well, I can only speak from experience as an avionics engineer for over 50 years, an avionics manufacturer for forty-three years, and an A&P IA for thirty years. Hardly any experience at all, and ALL of it in General Aviation.

    I started a business 43 years ago making KIT avionics. That's right, folks, Heathkits for Airplanes. And I didn't distinguish between experimentals and factory builts. After a year of this foolishness, the bigwigs from the FAA Western Region headquarters came down to give me a Stern Talking To. They said without STC,TSO,or PMA I couldn't build my stuff and sell it. I asked them to show me the STC/TSO/PMA for the Narco Superhomer/Mark III through Mark XII or the King STC/TSO/PMA for the KX 120/150/170.

    The answer was "Well, harumph, those are big companies and harrumph we think they make a good product and harrumph they don't or they haven't or they shouldn't or they won't ... well, anyway, we'll be getting back to you when we think this through."

    That was 42 years ago, the team leader for that group went on to become the Director of Airworthiness back in DC, and neither he nor any of his minions have been back to see me. My non TSO's/STC'd/PMA'd stuff have been installed in over TEN THOUSAND aircraft of all makes and models. Audio panels, marker receivers, 760 channel navcoms, lamp dimmers, intercoms ... the whole array of avionics. As yet, not a peep from the Friendly Aviation Agency.

    Now, would somebody that can speak from knowledge and experience like to debate me over what can and cannot be installed into standard (as opposed to experimental) certificated aircraft?

    Jim
     
  18. Checkout_my_Six

    Checkout_my_Six Final Approach

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    133 years of experience? :eek: now that's an internet expert if I ever saw one....btw, I work for John and the current director is a she. :lol:
     
  19. weirdjim

    weirdjim En-Route

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    Are you telling me I can't be an avionics engineer working for my own company while holding an A&P/IA? And the director I was referring to was a William that went by Bill. That was in 1974, probably before you were born, sonny.

    Jim
     
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  20. Checkout_my_Six

    Checkout_my_Six Final Approach

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    na.......I was well born before that...and in HS then. No, Bill here....just females. :D
     
    Last edited: Aug 8, 2017
  21. denverpilot

    denverpilot Taxi to Parking

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    "Went on to become" doesn't mean "currently is". Just sayin'.
     
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  22. Checkout_my_Six

    Checkout_my_Six Final Approach

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  23. darrell

    darrell Pre-takeoff checklist

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    So what's the rule? Is there a rule?
    Is there more than one rule? Is there a good resource for determining what can and can't be installed without an STC or some such? I'm terribly curious. I'm an A&P and soon ot be IA but with practically zero GA experience. I'm a private pilot, though, and just bought into a partnership on a (certified) plane that I hope to be able to help maintain and maybe even do some modifications to.
     
  24. weirdjim

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    If anybody can give a quote to a pertinent (PERTINENT) rule, let (s)he) him POST IT HERE. Until then, all you Monday Morning Quarterback Rule Folks just please be quiet (FOR PART 91 AIRCRAFT). Please, let's thrash this out once and for all for PART 91 AIRCRAFT (be them standard or experimental).

    Thanks,
    Jim
     
  25. JAWS

    JAWS Line Up and Wait

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    http://downloads.valavionics.com/INS_429_INSTALL_MANUAL_04-15 rev3.pdf
    http://www.valavionics.com/installation-in-type-certificated-aircraft.html
    http://edburkhead.com/ercoupe/TSO_Instrument_Requirement.htm
     
  26. brien23

    brien23 Cleared for Takeoff

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    I would think over the years this question of TSO would have been put to rest, not so I get the question all the time. Some of the avionics shops tell people it has to be TSO I tell them BS show me, they come up with some lame ref. and say that is the way it is. Your not going to change those who either don't know or think they know or those with other reasons like selling higher priced and the paperwork that goes with it.TSO or Non TSO it's never going to end.
    Part of the problem is in instruction of pilots, instructors have little or no knowledge of STC, TCDS, A/D compliance, log book sign off of a annual in only the airframe logbook what pilots can and can't work on it's the blind leading the blind.
     
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  27. Timbeck2

    Timbeck2 Final Approach

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    I wish I lived closer to Mr. Weir. :(

    It would sure save me a lot of money on avionics installs. Mechanics, specifically IA's around here don't know the meaning of "meets" TSO requirements and are too scared to install anything that doesn't have the stamp on it.
     
  28. hotprops

    hotprops Line Up and Wait

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    weird jim is correct ,part91 its ok. however you might have a problem selling a aircraft with non compliant avionics .
     
  29. thomasdr72

    thomasdr72 Pre-takeoff checklist

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    I have at least one gadget in my panel, that was specifically marketed to the Experimental market (ONLY). It took a few months to speak to the right people in the FAA, but I eventually ended up with the appropriate paperwork to have it installed under a Field Approval. And get this: it interfaces a non-TSO Garmin GPS to my legacy autopilot! It works beautifully, and was one of the best upgrades I ever installed... FWIW, you can get nearly any reasonable upgrade installed, if you are willing to do the legwork to have it approved. And yes, there are plenty of things that don't need approval anyway...

    The cost of getting the paperwork completed? Zero dollars, and some spare time equity...
     
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  30. bradg33

    bradg33 Cleared for Takeoff

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    If only field approvals were that easy in most parts of the country. The prevailing attitude at FSDOs, as the older inspectors retire, is that field approvals are forbidden. They can be next to impossible to obtain in many (or most) areas now (I've been trying to get one for a G5 for an airplane that isn't on the approved model list).
     
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  31. weirdjim

    weirdjim En-Route

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    That is the problem exactly. I come from an era where every FAA inspector had to have a lot of years getting grease under their fingernails. Today the paper diploma on the wall is the entry ticket and none of them could distinguish a piston rod from a valve push rod.

    I said to hell with it about ten years ago. I've been granted the wisdom from the Administrator with that little IA paper to distinguish airworthy from horsepuckey. It is MY determination what flies and what doesn't. And if some wet behind the ears FAA puke wants to challenge me I'll cut him/her into little tiny pieces on the witness stand. And if they choose to revoke my IA, what in the hell do I lose when I'm 73? Bogus signatures in the logbook? Try and trace THAT, folks

    I'm going over tomorrow morning to inspect a Cherokee muffler in accordance with a bull$#it AD that requires a looksee every 50 hours. I'm sure that one of the prissy inspectors expects me to fill the muffler with water and pressurize it to look for leaks. Guess what, I'm going to look for telltraces of white powder that ought to take me at least ten minutes and I'm going to swap the "inspection" for a plate of flapjacks down at the local mom-n-pop breakfast place.

    Aviation out in the boondocks is WAY different from those of you in the cities.

    Jim
     
  32. hotprops

    hotprops Line Up and Wait

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    I like car 3 more than part 21 .all they say re avionics is, it should not go on fire!!!
     
  33. Checkout_my_Six

    Checkout_my_Six Final Approach

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    unfortunately...Jim is right.

    There are a few that turn a wrench in their spare time....but a rarity.
     
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  34. darrell

    darrell Pre-takeoff checklist

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    I almost feel like the more I read in reference to this issue, the more confused I get. The problem is that I'm trying to find an actual honest-to-goodness government reference that prohibits non-TSO certified avionics and instruments for aircraft operated under Part 91, and I just can't find it. The only thing that comes close is FAA 8900.1 but they dropped the "Part 91" mention at least 3 years ago. Like I said previously, I have virtually no general aviation experience, being a low time private pilot. I am an A&P (soon to be IA) with a decent amount of experience (albeit in a narrow range of aircraft), just not in GA.

    Maybe the reason I can't find it is because it isn't there? Maybe it used to be required back when FAA 8900.1 (Volume 4, Chapter 14, Section 2, Paragraph 4-1378) mentioned Part 91 along with 121, 125, and 135, and people don't realize that Part 91 was dropped from that paragraph? Maybe (almost a certainty, really) I'm not looking in the right places?
     
  35. bradg33

    bradg33 Cleared for Takeoff

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    Will you come be my mechanic? Finding an A&P these days that isn't terrified of running afoul of the FAA isn't an easy task. I get it; a "working" A&P has a lot to lose if the FAA decides he/she has mis-stepped, but it's maddening for an owner.
     
  36. bradg33

    bradg33 Cleared for Takeoff

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    There isn't one. The regulatory aspects of what parts are "legal" to install in an airplane are comprised of a scattered mess of Advisory Circulars, FAA Orders, and vague regulatory wording (like "Approved Data" and "Data Acceptable to the Administrator."). With respect to TSOd equipment (not equipment that "meets" TSO, but that actually has a TSO), the FAA has said this part is acceptable to be installed in airplanes. That gives an A&P a lot of comfort and takes the burden (and liability) of that decision off his/her shoulders. Now that A&P just has to decide that the TSOd part can be installed in THIS airplane, which is generally an easier task. With STCd parts, the FAA has said this particular part can be installed in this particular airplane, which makes things REALLY easy for an A&P. You can see why A&Ps like TSOd stuff, but really, really prefer STCd stuff (with ultimate preference being factory parts). As far as I can tell, there is no rule that says an A&P can or cannot install non-TSOd, PMAd, or STCd parts on an certified airplane; the A&P has the legal authority to make that ultimate airworthiness decision and install the part. However, if the FAA decides the A&P was wrong, trouble is likely. If you're a working A&P counting on that job as your livelihood, what would you do?
     
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  37. thomasdr72

    thomasdr72 Pre-takeoff checklist

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    One of the things that worked well for me, is when I didn't get a reasonable answer from my local FSDO, I called the Chicago small airplane directorate. Then things moved pretty quickly, and a fair outcome happend within about 6 weeks (give or take). Those guys really do believe in common sense, and they are much of the reason that this new non-TSO gear is getting approved.

    It also helps to have a proposal package already drafted, so that immediately after your telephone call you can follow up with paperwork when it's fresh in their mind. My local FSDO issued the FA the same day that they received a consent letter from the Chicago office.

    Cheers!

    -Dana
     
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  38. bradg33

    bradg33 Cleared for Takeoff

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    I actually had a somewhat similar good experience with the SAD recently. I'm looking to install a new attitude indicator in my airplane, which weighs exactly 6,000lbs. The unit I want to install is the Sandia Quattro, which is a TSOd attitude indicator (along with a bunch of other stuff). There is a new-ish Policy Statement that says it's acceptable to replace a gyro attitude indicator with an electronic one as a minor alteration. However, the policy says it only applies to aircraft "under 6,000lbs," which excludes my airplane. Curiously, every other 6,000lb reference/barrier in the regulations reads "6,000lbs and under," meaning my airplane would be covered. My installer was generally comfortable with my proposal, especially after I spoke to an A&P friend who works at the FAA and he agreed that in any event the change is a minor alteration. That said, it would be more comforting if the Policy Statement could be relied upon. So I looked up the FAA directory and called the guy who signed the Policy Statement (acting manager of the Small Airplane Directorate). I left a voicemail, and he had one of his reports call me back (a manager himself). . I explained the situation, and he (shockingly) agreed with me that the Policy was inconsistent with the general regulatory scheme and that the intent of the Policy is to be "6,000lbs and under." He said he had no issue with me putting the digital AI in my airplane relying on the Policy Statement (as a minor alteration) and that I should feel free to have my installer call him directly for further guidance. He also suggested that he'd have the engineer who wrote the policy statement call me directly to discuss the "secondary" function issues.
     
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  39. bnt83

    bnt83 Final Approach PoA Supporter

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    Who wants to pay a mechanic shop rate labor to play phone tag with the FAA because the owner wants to install a mod that holds NO prior approval? That time alone would probably pay for the difference in cost.

    Ok, lets say they just installed it without the FAA consult, now the FAA somehow caught wind of it and the mechanic is forced to play the phone tag game because his kids gotta eat. Now he's probably gotta spend even more time defending his position, which may or may not be a successful outcome, and not got getting paid for the effort.
     
    Last edited: Aug 11, 2017
  40. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    Which is why an A&P would never use a zip tie or safety wire in place of a hose clamp on an air box.