Today's Message Index:
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1. 02:10 AM - Re: GRT GPS TSO (W J R HAMILTON)
2. 02:16 AM - Re: GRT GPS TSO (W J R HAMILTON)
3. 05:48 AM - Re: Re: GRT GPS TSO (Dennis Shoup)
Message 1
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Folks,
My comments were only directed at what seemed to
me, to be some confusion about RAIM versus
C145/146. I think my post has been taken a bit too widely.
Re. compliance standards for C145/146, believe me
the way the TSO (and RTCA docs.) are written,
they are very prescriptive, generic words about
alternative means of compliance, however
expressed, don't make much difference here. The
difference in price between C129a(still the
majority of production GPS, whether the final set
is TSO or not) is really quite dramatic.
As to FAA requirements for IFR flight, I'm not
buying into that, I have enough problems with our
own rules, but I would much rather be working
with the FAA system, it is quite reasonably
pragmatic and at least has some flexibility.
Cheers,
Bill Hamilton
----------
At 05:50 AM 10/01/2007, you wrote:
>
>1/9/2007
>
>Hello Bill,
>
>1) You wrote: " In some instances the regs
>require that a piece of equipment MUST MEET TSO
>STANDARDS. This is the case with transponders.
>In other instances the equipment MUST BE TSO'd.
>This is the case with IFR GPS units."
>
>Both TSO-145A and TSO-C146A dealing with IFR GPS
>units contain the following paragraph (MPS means
>Minimum Performance Standards):
>
>"g. Deviations. The FAA has provisions for using
>alternative or equivalent means of compliance to
>the criteria set forth in the MPS of this TSO.
>Applicants invoking these provisions shall
>demonstrate that an equivalent level of safety
>is maintained and shall apply for a deviation per 14 CFR =A7 21.609"
>
>2) TSO-C129a is an older TSO dealing with IFR
>GPS units and does not contain specific
>alternate compliance words within it as is the
>case with more current FAA TSO's, but here is a
>quote from the current AIM, note the use of the word "equivalent":
>
>"g. Equipment and Database Requirements.
>
>1. Authorization to fly approaches under IFR using GPS avionics systems
>requires that:
>(a) A pilot use GPS avionics with TSO- C129, or equivalent, authorization
in
>class A1, B1, B3, C1, or C3; and......"
>
>3) You wrote: "If simply meeting the TSO
>requirements is adequate, why should a
>manufacturer "go to the expense and effort"?"
>
>My point exactly. Simply meeting some of the TSO
>requirements is not adequate to fulfill the intent of the FAA TSO
requirements.
>
>GRT implies that they are completely fulfilling
>the FAA TSO intent by writing: "The new
>RAIM-equipped version provides integrity
>monitoring and 5 updates per second to meet the
>requirements of IFR GPS TSO C129 and C146."
>
>The equipment must either be TSO'd in accordance
>with the provisions of FAR Part 21 Subpart O or
>FAA deviation approval from the TSO in
>accordance with paragraph 21.609 must be
>obtained. Neither one of these are easy actions
>to take and there is no indication in the GRT
>statement posted that either action has been
>taken. Hence my suspicion of misleading weasel wording.
>
>OC -- The best investment we will ever make is in gathering knowledge.
>
>Time: 09:35:15 AM PST US
>From: "Bill Denton" <bdenton@bdenton.com>
>Subject: RE: AeroElectric-List: GRT GPS TSO
>
>"A piece of equipment either meets the full TSO requirements and is marked
>TSO compliant or it is not TSO'd."
>
>True, but not necessarily the point...
>
>In some instances the regs require that a piece of equipment MUST MEET TSO
>STANDARDS. This is the case with transponders.
>
>In other instances the equipment MUST BE TSO'd. This is the case with IFR
>GPS units.
>
>You mentioned, "...manufacturers who have gone to the expense and effort of
>obtaining TSO approval for a piece of equipment..."
>
>If simply meeting the TSO requirements is adequate, why should a
>manufacturer "go to the expense and effort"?
>
>
CONFIDENTIALITY & PRIVILEGE NOTICE
W.J.R.Hamilton,Glenalmond Group Companies,Fighter
Flights Internet Services and
Warbirds.Net.<wjrhamilton@optusnet.com.au> &
<GlenalmondEngineering@Gmail.com>
This message is intended for and should only be
used by the addressee. It is confidential and may
contain legally privileged information.If you are
not the intended recipient any use
distribution,disclosure or copying of this
message is strictly prohibited.Confidentiality
and legal privilege attached to this
communication are not waived or lost by reason of
the mistaken delivery to you.
If you have received this message in error,
please notify us immediately to: Australia 61 (0)408 876 526
Dolores capitis non fero. Eos do.
Message 2
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Folks,
My comments were only directed at what seemed to
me, to be some confusion about RAIM versus
C145/146. I think my post has been taken a bit too widely.
Re. compliance standards for C145/146, believe me
the way the TSO (and RTCA docs.) are written,
they are very prescriptive, generic words about
alternative means of compliance, however
expressed, don't make much difference here. The
difference in price between C129a(still the
majority of production GPS, whether the final set
is TSO or not) is really quite dramatic.
As to FAA requirements for IFR flight, I'm not
buying into that, I have enough problems with our
own rules, but I would much rather be working
with the FAA system, it is quite reasonably
pragmatic and at least has some flexibility.
Cheers,
Bill Hamilton
----------
At 05:50 AM 10/01/2007, you wrote:
>
>1/9/2007
>
>Hello Bill,
>
>1) You wrote: " In some instances the regs
>require that a piece of equipment MUST MEET TSO
>STANDARDS. This is the case with transponders.
>In other instances the equipment MUST BE TSO'd.
>This is the case with IFR GPS units."
>
>Both TSO-145A and TSO-C146A dealing with IFR GPS
>units contain the following paragraph (MPS means
>Minimum Performance Standards):
>
>"g. Deviations. The FAA has provisions for using
>alternative or equivalent means of compliance to
>the criteria set forth in the MPS of this TSO.
>Applicants invoking these provisions shall
>demonstrate that an equivalent level of safety
>is maintained and shall apply for a deviation per 14 CFR =A7 21.609"
>
>2) TSO-C129a is an older TSO dealing with IFR
>GPS units and does not contain specific
>alternate compliance words within it as is the
>case with more current FAA TSO's, but here is a
>quote from the current AIM, note the use of the word "equivalent":
>
>"g. Equipment and Database Requirements.
>
>1. Authorization to fly approaches under IFR using GPS avionics systems
>requires that:
>(a) A pilot use GPS avionics with TSO- C129, or equivalent, authorization
in
>class A1, B1, B3, C1, or C3; and......"
>
>3) You wrote: "If simply meeting the TSO
>requirements is adequate, why should a
>manufacturer "go to the expense and effort"?"
>
>My point exactly. Simply meeting some of the TSO
>requirements is not adequate to fulfill the intent of the FAA TSO
requirements.
>
>GRT implies that they are completely fulfilling
>the FAA TSO intent by writing: "The new
>RAIM-equipped version provides integrity
>monitoring and 5 updates per second to meet the
>requirements of IFR GPS TSO C129 and C146."
>
>The equipment must either be TSO'd in accordance
>with the provisions of FAR Part 21 Subpart O or
>FAA deviation approval from the TSO in
>accordance with paragraph 21.609 must be
>obtained. Neither one of these are easy actions
>to take and there is no indication in the GRT
>statement posted that either action has been
>taken. Hence my suspicion of misleading weasel wording.
>
>OC -- The best investment we will ever make is in gathering knowledge.
>
>Time: 09:35:15 AM PST US
>From: "Bill Denton" <bdenton@bdenton.com>
>Subject: RE: AeroElectric-List: GRT GPS TSO
>
>"A piece of equipment either meets the full TSO requirements and is marked
>TSO compliant or it is not TSO'd."
>
>True, but not necessarily the point...
>
>In some instances the regs require that a piece of equipment MUST MEET TSO
>STANDARDS. This is the case with transponders.
>
>In other instances the equipment MUST BE TSO'd. This is the case with IFR
>GPS units.
>
>You mentioned, "...manufacturers who have gone to the expense and effort of
>obtaining TSO approval for a piece of equipment..."
>
>If simply meeting the TSO requirements is adequate, why should a
>manufacturer "go to the expense and effort"?
>
>
CONFIDENTIALITY & PRIVILEGE NOTICE
W.J.R.Hamilton,Glenalmond Group Companies,Fighter
Flights Internet Services and
Warbirds.Net.<wjrhamilton@optusnet.com.au> &
<GlenalmondEngineering@Gmail.com>
This message is intended for and should only be
used by the addressee. It is confidential and may
contain legally privileged information.If you are
not the intended recipient any use
distribution,disclosure or copying of this
message is strictly prohibited.Confidentiality
and legal privilege attached to this
communication are not waived or lost by reason of
the mistaken delivery to you.
If you have received this message in error,
please notify us immediately to: Australia 61 (0)408 876 526
Dolores capitis non fero. Eos do.
Message 3
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Enough already!
On 1/9/07, W J R HAMILTON <wjrhamilton@optusnet.com.au> wrote:
>
> Folks,
> The difference between the performance of TSO'd equipment and apparently
> similar performance non-TSO'd equipment is not trivial.
>
> There are very good reasons for requiring RAIM in C-129a units, for most
> of the non-TSO units, there is no or inadequate internal monitoring of the
> position solution and navigation output, as the accident record shows, that
> can be seriously fatal.
>
> Please, please, please, everybody, don't go flying IFR with non-TSO GPS
> equipment, the database of demonstrated problems in the field is
> hair-raising.
> Just for starters, the integrity of the basic software (not the navigation
> database) is unknown.
>
> A hunt around the Australian CASA web site will find some interesting
> facts about incidents and accidents, world wide, using the wrong GPS in the
> wrong place, or drop Ian Mallet, head of the GNSS Office at CASA an email, I
> am certain he will provide you with some rather interesting references.
>
> Cheers,
> Bill Hamilton
>
>
> At 09:10 AM 10/01/2007, you wrote:
>
>
> 1/9/2007
>
> Hello Bret:
>
> 1) You wrote: "As you can see, the FAA has left a wide loophole with the
> phrase "or equivalent"."
>
> The FAA has learned from experience that locking technical requirements in
> bureaucratic documents in concrete can come back to bite them when
> technology comes up with a better mouse trap that was not envisioned in the
> document. So now-a-days they caveat their TSO's with a statement to the
> effect that "if you can do it just as good, but maybe a little differently
> we are willing to listen to your proposal."
>
> The process for a request to deviate is described in FAR 21.609 and the
> loophole is not that wide. You might find that entire FAR 21 Subpart O
> interesting reading. You can see that obtaining TSO approval and
> manufacturing in accordance with that approval can be burdensome.**
>
> 2) You wrote: "It appears that, from my understanding, a GPS used for IFR
> navigation must meet the minimum standard of RTCA/DO-208 in order to meet
> the standard of TSO-C129 in order to be approved for IFR navigation."
>
> I agree. Also realize that there are other documents referenced in
> TSO-C129a that may contain standards that the unit may have to meet. And the
> FAA may chose to not incorporate all provisions of referenced documents into
> the TSO. Some TSO's are absolutely infuriating -- they say nothing of
> substance technically themselves, but instead reference several documents
> (such as SAE documents) that cost a bunch of money for just three or four
> pages.
>
> 3) You wrote: "Problem is, I don't see where the FAA requires the GPS to
> be "certified".
>
> I agree. The words theFAA uses are "authorization (to perfom IFR
> operations) requires equipment approved IAW TSO -C129" (version C129a is the
> current version). Lawyers may not agree with me, but I bet the Garmin
> marketing people looked at the FAA terminology of "authorization" and
> "approved" and said "certified sounds better to us".
>
> 4) You wrote: "I may be confused here but it seems that when Garmin states
> their GNS430 is "IFR Approach Certified", they are only stating that this
> receiver meets the requirements of TSO-C129."
>
> I agree -- and also meeting all the pertinent references to TSO-C129a and
> permitting the FAA oversight of Garmin's production of the GNS 430. (See FAR
> 21.615).
>
> In addition now Garmin is stating that the GNS 430W meets all the
> requirements of TSO 146a.
>
> OC -- The best investment we will ever make is in gathering knowledge.
>
> **PS: I worked with Lance Turk, founder of Vision Microsystems, on a
> special size oil temperature probe for my TCM engine. He would not make the
> probe for me because it would be non TSO'd and he did not want to
> contaminate his FAA TSO approved production line. I wound up buying an empty
> brass temperature probe body from Westach and sending it to Lance so that he
> could have one of his technicians epoxy one of the Vision Microsystems
> special oil temperature probe sensors into that brass body's cavity. Works
> like a charm.
>
> ----- Original Message ----- From: "Bret Smith" <smithhb@tds.net>
> To: <bakerocb@cox.net>
> Sent: Tuesday, January 09, 2007 3:19 PM
> Subject: Re: GRT GPS TSO
>
>
> OC,
>
> This is truly fascinating.
>
> You said >
> 4) If you had only a non TSO'd GPS aboard and performed a specific
> operation
> that the AIM required a TSO approved GPS for then you would not be in
> compliance with 1E and may be subject to a charge of careless or reckless
> T
> operation (see FAR 91.13).
>
> A brief perusal of the AIM revealed: (italics mine)
>
> AIM 1-1-19
> d. General Requirements
>
> 1. Authorization to conduct any GPS operation under IFR requires that:
>
> (a) GPS navigation equipment used must be approved in accordance
> with the requirements specified in Technical Standard Order (TSO) TSO-C129,
> or equivalent, and the installation must be done in accordance with Advisory
> Circular AC 20-138, Airworthiness Approval of Global Positioning System
> (GPS) Navigation Equipment for Use as a VFR and IFR Supplemental Navigation
> System, or Advisory Circular AC 20-130A, Airworthiness Approval of
> Navigation or Flight Management Systems Integrating Multiple Navigation
> Sensors, or equivalent. Equipment approved in accordance with TSO-C115a does
> not meet the requirements of TSO-C129.
>
> The words "must be approved..." pretty much settles the issue with me.
> Then they continue on with the phrase "or equivalent". What would be
> equivalent to TSO-C129? So off I go to read TSO-C129....
>
>
> http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/e560cd9c6acf8ba186256dc700717e0f/$FILE/C129a.pdf
>
> I now know the requirements of any GPS to meet the TSO...
>
> "Airborne supplemental area navigation equipment using GPS that are
> to be so identified and that are manufactured on or after the date of this
> TSO must meet the minimum performance standard of Section 2, RTCA,
> Inc. Document No. RTCA/DO-208, "Minimum Operational Performance Standards
> for Airborne Supplemental Navigation Equipment Using Global Positioning
> System (GPS)," dated July 1991."
>
> See the RTCA/DO-208 document here...
> http://www.navcen.uscg.gov/cgsic/meetings/summaryrpts/31stmeeting/chesto/chesto.pdf
>
> As you can see, the FAA has left a wide loophole with the phrase "or
> equivalent". It appears that, from my understanding, a GPS used for IFR
> navigation must meet the minimum standard of RTCA/DO-208 in order to meet
> the standard of TSO-C129 in order to be approved for IFR navigation.
>
> Problem is, I don't see where the FAA requires the GPS to be "certified".
> I may be confused here but it seems that when Garmin states their GNS430 is
> "IFR Approach Certified", they are only stating that this receiver meets the
> requirements of TSO-C129.
>
> Your thoughts are appreciated.
>
> Bret
>
>
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>
>
> *CONFIDENTIALITY & PRIVILEGE NOTICE
> *W.J.R.Hamilton,Glenalmond Group Companies,Fighter Flights Internet
> Services and Warbirds.Net.<wjrhamilton@optusnet.com.au> & <
> GlenalmondEngineering@Gmail.com>
> This message is intended for and should only be used by the addressee. It
> is confidential and may contain legally privileged information.If you are
> not the intended recipient any use distribution,disclosure or copying of
> this message is strictly prohibited.Confidentiality and legal privilege
> attached to this communication are not waived or lost by reason of the
> mistaken delivery to you.
> If you have received this message in error, please notify us immediately
> to: Australia 61 (0)408 876 526
> *Dolores capitis non fero. Eos do.
>
> *
>
>
> *
>
> *
>
>
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