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20 Jun 2025, 07:58 [ UTC - 5; DST ]


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 06 Apr 2016, 13:28 
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Username Protected wrote:
Garmin has a new small form AHRS from their experimental team that looks awesome.

What are the rules on putting that in an empty hole in the panel of a certified plane. Assuming you meet all the other requirements with your certified instruments, is it legal to have an experimental 'backup' in the panel?

Seems no different than velcroing an iPad to your panel but I acknowledge I don't know the rules on these things.

The ultimate example would be could I legally replace the backup 6 pack in front of the right seat of my plane with a G3 touch.


This is a great question and I was wondering the very same thing. That AHRS is only $2000 and I would like it to go with my ASPEN. I would like an ADSB solution along these lines as well.

There are 3 things the FAA could do for GA: 1. Relax the regulations on avionics; 2. allow owners more latitude in performing basic maintenance; and 3. remove the annual inspection and replace it with a 200hr or two year inspection that is less comprehensive than the annual; otherwise inspect and repair on condition.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 06 Apr 2016, 13:40 
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Username Protected wrote:

There are 3 things the FAA could do for GA: 1. Relax the regulations on avionics; 2. allow owners more latitude in performing basic maintenance; and 3. remove the annual inspection and replace it with a 200hr or two year inspection that is less comprehensive than the annual; otherwise inspect and repair on condition.


Hear, hear! :clap:

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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 06 Apr 2016, 16:27 
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Username Protected wrote:
Friend just got field approval for Dynon D-1000 in his C-310-R
As long as the certified gauges that came with the plane are in pilots view


Can you clarify whether the field approval is for the Dynon Skyview (SV-D1000) or the older generation D-100? And will they retain IFR capability in the aircraft post install?


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 06 Apr 2016, 17:25 
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Can you post the 337 so the rest of can use that a basis for a follow on 337, what FSDO?

I am going to submit for a 337 for the G3X touch in the P Baron retaining the existing steam stuff on the copilots side.

This is a step in the right direction to save GA.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 06 Apr 2016, 17:40 
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Username Protected wrote:
Can you post the 337 so the rest of can use that a basis for a follow on 337, what FSDO?

I am going to submit for a 337 for the G3X touch in the P Baron retaining the existing steam stuff on the copilots side.

This is a step in the right direction to save GA.


That will be interesting to see if you get approval - especially in a 6000+ lb airplane and putting it on the pilot's side with the certified on the co-pilot side.

IMO, the G3X touch with autopilot should be allowed in ANY airplane under 125000 as primary.

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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 07 Apr 2016, 21:17 
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The new Garmin G5 could possibly be installed if you added a second Pitot tube.
Some aircraft such as the Baron 58TC and P have provisions for a second Pitot tube and it could simply be installed and connected to the G5. The static would be a different problem however. In a non-pressurized it could simply vent to the cabin and likely work well as a backup?


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 08 Apr 2016, 19:27 
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I'm real curious about the G3X touch installation... This would be nice - even with the limitations described.

-jason

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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 11 Apr 2016, 00:52 
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I've been asked by a few folks to post a copy of my 337 for the G3X Touch. My FISDO approves installations in two stages: first the data is approved... FAA signs the 337, then when the installation is complete the paperwork is signed by the IA, and sent back to FAA so that it can be filed with OK City. I have not yet completed the installation. So give me a little time to complete the installation and get everything finalized prior to giving FAA reason to re-think this approval because of all the attention. I doubt that would happen, but ... :beechslap: you never know.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 14 Apr 2016, 15:35 
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I think a lot of us are salivating over the proposed rule changes that's long over due maybe some day before I retire I hope and I'm only 49 LOL awesome news though I didn't know they would even consider it before the old thinker is in over drive.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 14 Apr 2016, 15:49 
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I agree this is all exciting to talk about...or dream about is probably more accurate. I have dual a G3X Touch setup in my Tecnam and love it. I think the G3X Touch provides at least a many capabilities as the G1000 but at a much lower cost.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 15 Apr 2016, 11:54 
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Username Protected wrote:

There are 3 things the FAA could do for GA: 1. Relax the regulations on avionics; 2. allow owners more latitude in performing basic maintenance; and 3. remove the annual inspection and replace it with a 200hr or two year inspection that is less comprehensive than the annual; otherwise inspect and repair on condition.


I'd like to hear opinions from the IAs on this. I like your ideas. I helped a friend yesterday doing an annual on a TR182 that has been a nightmare. At what point does an inspection become a restoration? This probably deserves its own thread from the maintenance guys.


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 15 Apr 2016, 12:38 
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I decided to install a G3X in the co-pilot's panel of my Cessna 340. After a somewhat lengthy FAA interchange with assistance from the Aircraft Electronic Association's counsel it was determined that the installation may be accomplished as a Minor Alteration with several obvious caveats. The primary consideration that must be addressed is PMA versus no PMA (cited as 21.9 below) and the associated rationale.

It is unclear to me whether it is permissible to tap in to the pitot and static system of the aircraft if you only have one system. My installation includes two separate pitot and static systems so it was not a consideration since it didn't modify the aircraft or its required equipment.

Here is the response from the FAA :

We have consulted with AFS and reviewed the current regulations and policies related to this request. Our conclusion is that under the existing guidance it is possible to install this type of system as a minor alteration provided the installation follows the guidance and Assistant Chief Counsel for Regulations’ published interpretation, and the issue of §21.9 for the part pedigree is addressed.

Consideration must be given for the installation under §21.9. This is a requirement placed on the producer not the installer but, given our knowledge of both parties, we would have to reject the installation until this was addressed. Assuming this could be dealt with, the remaining installation issues have been evaluated as follows:

Both the AFS-300 Major Repair/Alteration Data Approval Job Aid and Chief Counsel’s interpretation are clear that an STC would be needed if this system were to replace any required systems or integrated with complex switching interfaces with other equipment and systems. This includes not only those required by § 91.205 but also § 23.1311, the stand-by instruments, or any other operating rule such as part 135 operations that require two pilots (example IFR operation without an operating autopilot).

In submitter's February 4, 2015 letter describing their proposed project, they state it is not intended to replace instrumentation required plus five other criteria. A better clarification of a minor alteration would be:

(a) It will not replace instrumentation required by the aircraft manufacturer’s standard equipment list,

(b) It will not serve as instrumentation required by any regulation including part 23, 91 or 135,

(c) The installation is accomplished in accordance with A.C. 43.13-2B,

(d) The device is appropriately placarded, and it is clear that it cannot be used as the source for required flight information by any required flight crew,

(e) If is installed on a non-interference basis with other equipment,

(f) The installed device is not used to drive or supply navigational information to a device that is required by FAR or as part of the aircraft original equipment,

(g) The system does not perform critical functions or is highly integrated with complex switching interfaces with other equipment and systems,

(h) Appropriate entries are recorded in the aircraft logbook, including modification to the aircraft weight and balance.


Geoff


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 15 Apr 2016, 12:45 
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I'm no expert, Geoff, but I think what you just shared is significant!


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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 15 Apr 2016, 13:19 
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Consideration must be given for the installation under §21.9. This is a requirement placed on the producer not the installer but, given our knowledge of both parties, we would have to reject the installation until this was addressed.

This is subtle.

Here's 21.9:

21.9 Replacement and modification articles.

(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is—

(1) Produced under a type certificate;

(2) Produced under an FAA production approval;

(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification;

(4) A commercial part as defined in § 21.1 of this part;

(5) Produced by an owner or operator for maintaining or altering that owner or operator's product; or

(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter.

(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.

(c) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person may not sell or represent an article as suitable for installation on an aircraft type-certificated under §§ 21.25(a)(2) or 21.27 unless that article—

(1) Was declared surplus by the U.S. Armed Forces, and

(2) Was intended for use on that aircraft model by the U.S. Armed Forces.


So you would not meet any part of 21.9(a). Not under TC, not under PMA, not standard, not commercial part, not owner produced, not made by a certificate holder.

But, you do meet 21.9(b). The device was not sold or represented as suitable for TC aircraft. The fact it was approved to be used that way doesn't change the fact it wasn't sold that way.

But if you get approved, and others start doing this, then doesn't Garmin "should know" the part is "reasonably likely" to be installed in TC aircraft?

This is a strange state of affairs.

Mike C.

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 Post subject: Re: experimental avionics as backups in certified plane
PostPosted: 15 Apr 2016, 13:29 
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Username Protected wrote:
I'm no expert, Geoff, but I think what you just shared is significant!



No kidding. I wonder if he now flies from the right seat.
Kevin


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