TRIG TN72 X ADS-B GPS Receiver

[Eric Bick (DY)]

TRIG shows a new product on their website - TN72 X GPS Receiver (which couples with a cheaper GPS antenna than the TA70 WAAS antenna). They now show 2 TN72 versions - one with label TABS (SIL=1) and one with label X (SIL=3) on the face of the box. The TABS can be installed on experimental or certified gliders giving ADS-B, but not 2020 compliant (which is what TABS was intended for originally). They say the X version, set at SIL=3, for LSA, homebuilt, and experimental gliders, has been flown in rule airspace and meets full 2020 compliance, per the FAA automated test flight software. The specs for the TABS and X versions in their brochure are identical (and TRIG says they are identical) - the only difference is one is set to TABS (SIL=1) and the other, X version, set to SIL=3, which means 2020 compliance for ruled airspace. Anyone know what is going on? And, more importantly, are they moving toward demonstrating a more cost effective solution to 2020 compliant ADS-B for certified gliders (as well as experimental), enabling them to use the TN72 and X with standard GPS antenna at about 1/4 the cost of the TN70 GPS receiver and TA70 WAAS antenna?

[Darryl Ramm]

On Monday, January 6, 2020 at 9:38:47 PM UTC-8, Eric Bick (DY) wrote:
> TRIG shows a new product on their website - TN72 X GPS Receiver (which couples with a cheaper GPS antenna than the TA70 WAAS antenna). They now show 2 TN72 versions - one with label TABS (SIL=1) and one with label X (SIL=3) on the face of the box. The TABS can be installed on experimental or certified gliders giving ADS-B, but not 2020 compliant (which is what TABS was intended for originally). They say the X version, set at SIL=3, for LSA, homebuilt, and experimental gliders, has been flown in rule airspace and meets full 2020 compliance, per the FAA automated test flight software. The specs for the TABS and X versions in their brochure are identical (and TRIG says they are identical) - the only difference is one is set to TABS (SIL=1) and the other, X version, set to SIL=3, which means 2020 compliance for ruled airspace. Anyone know what is going on? And, more importantly, are they moving toward demonstrating a more cost effective solution to 2020 compliant ADS-B for certified gliders (as well as experimental), enabling them to use the TN72 and X with standard GPS antenna at about 1/4 the cost of the TN70 GPS receiver and TA70 WAAS antenna?

I've covered this all before on r.a.s. There is nothing new, this is all old news, the "different models" TN72 were launched around one to two years ago. Trig make great products but unfortunately have tripped up here on basic marketing, and are just confusing customers... all in an effort that was intended to make things clearer. Not sure how that was ever supposed to work. I suggested they not use this confusing naming, but they did. Nothing has changed recently with GPS antennas either, the TA50 has been available for a long time.

The TN72 GPS never unchanged, it's the same box it has always been. Wether an installer can claim it is SIL=3 or SIL=1 depends on whether the install is in an experimental aircraft (you can claim SIL=3/2020 compliant) possible) or a type certified (you can't claim SIL=3 so do SIL=1/TABS).

No difference in these TN72 GPS device models at all. It's just what you tell the transponder is attached. ... and uh no don't try to cheat and set SIL=3 in a type certified aircraft... you are flying around broadcasting the SIL=3 flag, and the FAA has a database of type certified aircraft that have "real" ADS-B out installs from A&P IA submitting Form 337s for ADS-B out installs in type certified aircraft... and yours won't be there. Are you athletic enough to squeeze out of the bathroom window while the feds are knocking on your front door? :-) I'm not. All pretty frustrating , specially for gliders, but hey I did not invent the regulations.

What *exactly* would it take under current regulations and FAA policy to be able to use a low-cost (say non-TSO-C145c) GPS to do full 91.227/2020 Complaint ADS-B Out in a type certified aircraft? I don't know. But the core step there would be to develop an installation STC. And that's likely to need a lot more work than with a already approved say TSO-C145c GPS, and I suspect that is not economically justifiable given a likely small total increase in market made possible. That the TN72 is separately TSO-C199 approved has no bearing at all on 91.227/2002 compliance. It might as well be TSO-ed as an aviation cigarette lighter adapter (TSO-C71 for those playing along at home).

[5Z]

And of course there's the joke of Standard vs Experimental gliders, such as the ASW-27. Looking on the FAA database, first thing is that there are 3 manufacturer/model codes containing 3, 5, and 73 gliders for a total of 81. Of these, there are 47 Standard, 21 Experimental, and 14 Unknown (Experimental?).

Beyond paperwork, there's no difference between Standard and Experimental (except for a few customized ones). Gotta love FAA and consistency.

[Eric Greenwell[_4_]]

5Z wrote on 1/7/2020 8:53 PM:
> And of course there's the joke of Standard vs Experimental gliders, such as the ASW-27. Looking on the FAA database, first thing is that there are 3 manufacturer/model codes containing 3, 5, and 73 gliders for a total of 81. Of these, there are 47 Standard, 21 Experimental, and 14 Unknown (Experimental?).
>
> Beyond paperwork, there's no difference between Standard and Experimental (except for a few customized ones). Gotta love FAA and consistency.
> Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
allowing us to put our gliders in the Experimental category? I think we should
appreciate the opportunity instead of deriding them.

--
Eric Greenwell - Washington State, USA (change ".netto" to ".us" to email me)
- "A Guide to Self-Launching Sailplane Operation"
https://sites.google.com/site/motorgliders/publications/download-the-guide-1

[5Z]

On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:

> Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
> allowing us to put our gliders in the Experimental category? I think we should
> appreciate the opportunity instead of deriding them.

That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?

5Z

[Scott Williams[_2_]]

On Wednesday, January 8, 2020 at 1:17:29 PM UTC-6, 5Z wrote:
> On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:
>
> > Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
> > allowing us to put our gliders in the Experimental category? I think we should
> > appreciate the opportunity instead of deriding them.
>
> That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?
>
> 5Z

at least there is a less expensive option for experimental. FAA could have adopted the position That if it flies, 2020 full compliance required.
Cheers,
Scott

[Craig Funston[_3_]]

On Wednesday, January 8, 2020 at 1:55:57 PM UTC-8, Scott Williams wrote:
> On Wednesday, January 8, 2020 at 1:17:29 PM UTC-6, 5Z wrote:
> > On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:
> >
> > > Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
> > > allowing us to put our gliders in the Experimental category? I think we should
> > > appreciate the opportunity instead of deriding them.
> >
> > That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?
> >
> > 5Z
>
> at least there is a less expensive option for experimental. FAA could have adopted the position That if it flies, 2020 full compliance required.
> Cheers,
> Scott
I have a brand new Trig TA70 antenna that's surplus to my needs. I ordered it prior to knowing that Experimental aircraft could use a smaller antenna. All reasonable offers entertained.

Craig Funston

[Eric Greenwell[_4_]]

Craig Funston wrote on 1/8/2020 3:03 PM:
> On Wednesday, January 8, 2020 at 1:55:57 PM UTC-8, Scott Williams wrote:
>> On Wednesday, January 8, 2020 at 1:17:29 PM UTC-6, 5Z wrote:
>>> On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:
>>>
>>>> Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
>>>> allowing us to put our gliders in the Experimental category? I think we should
>>>> appreciate the opportunity instead of deriding them.
>>>
>>> That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?
>>>
>>> 5Z
>>
>> at least there is a less expensive option for experimental. FAA could have adopted the position That if it flies, 2020 full compliance required.
>> Cheers,
>> Scott
> I have a brand new Trig TA70 antenna that's surplus to my needs. I ordered it prior to knowing that Experimental aircraft could use a smaller antenna. All reasonable offers entertained.
>
I believe if you use it with your TN72, you can be fully 2020 compliant - not just
TABS compliant.


--
Eric Greenwell - Washington State, USA (change ".netto" to ".us" to email me)
- "A Guide to Self-Launching Sailplane Operation"
https://sites.google.com/site/motorgliders/publications/download-the-guide-1

[Darryl Ramm]

On Wednesday, January 8, 2020 at 1:55:57 PM UTC-8, Scott Williams wrote:
> On Wednesday, January 8, 2020 at 1:17:29 PM UTC-6, 5Z wrote:
> > On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:
> >
> > > Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
> > > allowing us to put our gliders in the Experimental category? I think we should
> > > appreciate the opportunity instead of deriding them.
> >
> > That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?
> >
> > 5Z
>
> at least there is a less expensive option for experimental. FAA could have adopted the position That if it flies, 2020 full compliance required.
> Cheers,
> Scott

Please be careful how you say this. An experimental install done properly is fully 14 CFR 91.227/2020 Compliant. This keeps causing confusion, with people sometimes thinking they should pay more for say a TN70 because it's "better". There is absolutely nothing "non-2020 compliant" or any reduction in ADS-B functionality or reduction in performance implied in using a "meets 14 CFR 91.227 requirements" GPS source in an experimental install vs say a TSO-C145c GPS source in a type certified aircraft install. It's literally the formal requirements for 2020 Compliance you are meeting, so it's just wrong to describe that ever as not "full 2020" compliance.

What you likely meant to say is the FAA did not require us to meet that performance requirement with a TSO approved GPS source.... and initially they effectively actually did, although they claim that was an unintentional oversight, AOPA and the EAA and AOPA took them to task on that and the regulations were modified.

[2G]

On Wednesday, January 8, 2020 at 3:50:25 PM UTC-8, Darryl Ramm wrote:
> On Wednesday, January 8, 2020 at 1:55:57 PM UTC-8, Scott Williams wrote:
> > On Wednesday, January 8, 2020 at 1:17:29 PM UTC-6, 5Z wrote:
> > > On Wednesday, January 8, 2020 at 5:29:50 AM UTC-8, Eric Greenwell wrote:
> > >
> > > > Consistent or not, or a bureaucratic stumble, aren't we better off with the FAA
> > > > allowing us to put our gliders in the Experimental category? I think we should
> > > > appreciate the opportunity instead of deriding them.
> > >
> > > That part I like. What I don't is that they differentiate Std/Exp when it comes to ADS-B installation. Why does the certificate make the radio operate differently?
> > >
> > > 5Z
> >
> > at least there is a less expensive option for experimental. FAA could have adopted the position That if it flies, 2020 full compliance required.
> > Cheers,
> > Scott
>
> Please be careful how you say this. An experimental install done properly is fully 14 CFR 91.227/2020 Compliant. This keeps causing confusion, with people sometimes thinking they should pay more for say a TN70 because it's "better". There is absolutely nothing "non-2020 compliant" or any reduction in ADS-B functionality or reduction in performance implied in using a "meets 14 CFR 91.227 requirements" GPS source in an experimental install vs say a TSO-C145c GPS source in a type certified aircraft install. It's literally the formal requirements for 2020 Compliance you are meeting, so it's just wrong to describe that ever as not "full 2020" compliance.
>
> What you likely meant to say is the FAA did not require us to meet that performance requirement with a TSO approved GPS source.... and initially they effectively actually did, although they claim that was an unintentional oversight, AOPA and the EAA and AOPA took them to task on that and the regulations were modified.

I think that it is fortunate that the FAA allows us a path to install non-TSO compliant GPS source, albeit in experimental category aircraft only (I did it on my new ASH31Mi). One should not be surprised that standard category aircraft are required to use TSO certified equipment. Perhaps someone out there has gone thru the hoops of switching from certificated to experimental. I would think that you would have to have some significant reason for doing this.

Tom

[[email protected]]

Perhaps someone out there has gone thru the hoops of switching from certificated to experimental. I would think that you would have to have some significant reason for doing this.
>
Lots of people have gone from Standard to Experimental, and the hoops aren't complex at all. You just request to change your Certificate of Airworthiness, get an inspection and new Operating Limitations and file an annual Program Letter with your local FSDO. I am probably going to do that this year, primarily so I can do more of my own work on the glider and also to take advantage of the simpler and cheaper "meets 14 CFR 91.227 requirements" GPS source.

Now, the big caveat is that it is hugely complex and difficult to go BACK to Standard Type from Experimental.

[Charles Longley]

You can’t do your “own work on” an experimental glider anymore than you can do on a type certified one. Either one requires an A&P or a Repairman to sign it off. Except for preventative maintenance which a rated pilot can do in either case.

[[email protected]]

Yes, but I can get my own work signed off much easier than having to have an A&P do the work at a much higher labor rate, field approvals and 337's are not as much of an issue, and considering the amount of grief the FAA put me through over the 3,000 hour Pegase life limit, I don't want to have any more contact with their bureaucracy than is absolutely necessary.

ps. I already do some stuff for the local A&P for other aircraft he is working on. I.E., machining, welding, electrical, O2 system installations, etc.

[jfitch]

On Thursday, January 9, 2020 at 6:04:11 AM UTC-8, wrote:
> Yes, but I can get my own work signed off much easier than having to have an A&P do the work at a much higher labor rate, field approvals and 337's are not as much of an issue, and considering the amount of grief the FAA put me through over the 3,000 hour Pegase life limit, I don't want to have any more contact with their bureaucracy than is absolutely necessary.
>
> ps. I already do some stuff for the local A&P for other aircraft he is working on. I.E., machining, welding, electrical, O2 system installations, etc.

My understanding is there is little difference between Exp and Standard catagories as far as maintenance and repair work. Both must be done under the supervision of, and signed off by certified persons. That means you can do the work provided those rules are met. I believe this is often confused with a homebuilt aircraft, which operate as experimental but under a different set of rules: the manufacturer can always work on their aircraft, and the builder is considered to be the manufacturer. Not true of a German built glider operating with an experimental certificate. That is my understanding, and I'd like to be corrected if it is wrong.

[Charles Longley]

On Thursday, January 9, 2020 at 10:05:59 AM UTC-8, jfitch wrote:
> On Thursday, January 9, 2020 at 6:04:11 AM UTC-8, wrote:
> > Yes, but I can get my own work signed off much easier than having to have an A&P do the work at a much higher labor rate, field approvals and 337's are not as much of an issue, and considering the amount of grief the FAA put me through over the 3,000 hour Pegase life limit, I don't want to have any more contact with their bureaucracy than is absolutely necessary.
> >
> > ps. I already do some stuff for the local A&P for other aircraft he is working on. I.E., machining, welding, electrical, O2 system installations, etc.
>
> My understanding is there is little difference between Exp and Standard catagories as far as maintenance and repair work. Both must be done under the supervision of, and signed off by certified persons. That means you can do the work provided those rules are met. I believe this is often confused with a homebuilt aircraft, which operate as experimental but under a different set of rules: the manufacturer can always work on their aircraft, and the builder is considered to be the manufacturer. Not true of a German built glider operating with an experimental certificate. That is my understanding, and I'd like to be corrected if it is wrong.

That is exactly correct. The builder of a homebuilt experimental aircraft (could be a glider) is usually issued a Repairman license for that particular aircraft by serial number.
The only other real difference is who can sign of a major alteration or repair. Generally a FAA from 337 isn't required for experimental aircraft. (There are some exceptions.)

[Darryl Ramm]

On Thursday, January 9, 2020 at 10:05:59 AM UTC-8, jfitch wrote:
> On Thursday, January 9, 2020 at 6:04:11 AM UTC-8, wrote:
> > Yes, but I can get my own work signed off much easier than having to have an A&P do the work at a much higher labor rate, field approvals and 337's are not as much of an issue, and considering the amount of grief the FAA put me through over the 3,000 hour Pegase life limit, I don't want to have any more contact with their bureaucracy than is absolutely necessary.
> >
> > ps. I already do some stuff for the local A&P for other aircraft he is working on. I.E., machining, welding, electrical, O2 system installations, etc.
>
> My understanding is there is little difference between Exp and Standard catagories as far as maintenance and repair work. Both must be done under the supervision of, and signed off by certified persons. That means you can do the work provided those rules are met. I believe this is often confused with a homebuilt aircraft, which operate as experimental but under a different set of rules: the manufacturer can always work on their aircraft, and the builder is considered to be the manufacturer. Not true of a German built glider operating with an experimental certificate. That is my understanding, and I'd like to be corrected if it is wrong.

My understanding as well.

But more importantly I think folks need to be careful with an aircraft that was moved from standard/type certified to experimental racing/exhibition. You don't escape from lots of stuff as for that aircraft "the FAA has previously issued a different kind of airworthiness certificate for that aircraft;" and therefore 14 CFR 41 (b)(1) applies and captures that aircraft back into Part 41 requirements.

"(b) This part does not apply to -

(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft;"

----

Transferring a standard type certificated aircraft to experimental exhibition/racing does not seem to me to remove say approval requirements for major alterations. Now wether a FSDO took a different level of interest in things and wanted more or less justification in an approval, who knows. After the NTSB investigation about he Galloping Ghost crash at Reno I wonder if FSDOs are paying more attention to all major alterations to racing and exhibition aircraft.

And on the other hand I hear about things, sometimes just crazy stuff, where I suspect folks are taking way too hard an interpretation of what is a major alteration in type certified gliders. This especially can happen if gliders are taken to say airframe or avionics shops that have no experience working with gliders.

As for ADS-B out installations, the regulations and policies are fairly complex when you dig into the lowest levels (much easy if you understand the policies apply and just follow them :-)) and I don't understand all the details, and not sure anybody really does, including even avionics manufacturers. I have questions into the FAA office of Chief Counsel asking about specific details with ADS-B Out installation regulations and policies.

My quick re-read of the AFS-360 March 2, 2016 Memo and AFS-360-2017-1 technical paper that describe the FAA ADS-B out installation policy (for type certified aircraft) is those policies do not seem to capture experimental aircraft that were previously type certified--since the preamble to each is similar stating the policies apply to "civil aircraft certificated under Title 14, Code of Federal Regulations (14 CFR) Parts 23, 25, 27, 29". However it may be a bit more complex that that, and do not rely on me for legal interpretation here.

[Bob Kuykendall]

On Wednesday, January 8, 2020 at 9:11:31 PM UTC-8, Charles Longley wrote:
> You can’t do your “own work on” an experimental glider anymore than you can do on a type certified one. Either one requires an A&P or a Repairman to sign it off. Except for preventative maintenance which a rated pilot can do in either case.

As an EAA technical counselor, I can say that that's almost always wrong. The operating limitations attached to the airworthiness certificate have the final say, but in all cases I've ever checked, there are no limitations about who can work on an amateur-built or racing experimental aircraft; 14CFR43 does not apply to them. The only thing you need certification for is signing off the annual condition inspection, and that's what requires the Repairman Certificate or A&P rating.

--Bob K.

[Bob Kuykendall]

On Thursday, January 9, 2020 at 11:32:07 AM UTC-8, Charles Longley wrote:

> That is exactly correct. The builder of a homebuilt experimental aircraft (could be a glider) is usually issued a Repairman license for that particular aircraft by serial number...

Here's the official EAA position on that:

https://www.eaa.org/eaa/aircraft-building/intro-to-aircraft-building/frequently-asked-questions/non-builder-maintenance

--Bob K.

[Charles Longley]

Right Bob but the guy was talking about going from a standard airworthiness certificate to experimental in which case part 43 would still apply.