ADSB visibility with non certified GPS

On Friday, September 22, 2017 at 9:11:34 AM UTC-7, Dan Marotta wrote:
This is very confusing.Â* So a TN72 is not a TSO device, but is compliant
and therefore can be mounted in an experimental aircraft which will be
seen by all compliant ADS-B In systems?Â* I feel cheated by having a
certificated aircraft!

On 9/21/2017 8:31 PM, Darryl Ramm wrote:
Walt, I think you are misunderstanding what Trig wrote. A TN72 GPS Source will be seen by everybody. That is why anybody doing ADS-B Out in an experimental glider with a TT22 should be equipping with at least a TN72 (or TN70, TN70 required for certified gliders).

--
Dan, 5J

You, and everybody else will continue to be confused if you keep talking about "TSO" and not specifying what TSO you are talking about. This caused lot of unneeded confusion and many posts on r.a.s. when the TN72 was announced. I don't know how many times I;ve already pointed this out.

The TN72 is a TSO-C199 Class B (aka TABS GPS source) device. Which from a regulation point of view makes no difference, since there are no installation or usage regulations that cover TSO-C199 devices. But since it is TSO-C199 we know important things about it's GPS quality, SIL parsameters, etc. and how it will interact with IFR GPS receivers and ground infrastructure.

The TN72 is Not TSO-C145 (requited for ADS-B Out in certified aircraft)

The TN72 does not meet TSO-C145 requirements (so can't be used for ADS-B Out in experimental aircraft where you want to us it to meet 2020 carriage requirements, in the case of gliders can't be used to meet requirements in the few areas where exemptions don't cover).

---

But yes I agree on the "feeling cheated" part in general, it points out the regulations are kinda stupid, especially when applied to gliders.

Darryl,

You said "The TN72 does not meet TSO-C145 requirements (so can't be used for ADS-B Out in experimental aircraft where you want to use it to meet 2020 carriage requirements, in the case of gliders can't be used to meet requirements in the few areas where exemptions don't cover)."

For those of us who cannot keep up, would you kindly list the requirements where the exemptions don't cover?

Many thanks!
-John

On Friday, September 22, 2017 at 11:48:33 AM UTC-7, John Carlyle wrote:
Darryl,

You said "The TN72 does not meet TSO-C145 requirements (so can't be used for ADS-B Out in experimental aircraft where you want to use it to meet 2020 carriage requirements, in the case of gliders can't be used to meet requirements in the few areas where exemptions don't cover)."

For those of us who cannot keep up, would you kindly list the requirements where the exemptions don't cover?

Many thanks!
-John

John

Start thinking more like a lawyer. Since gliders have broad ADS-B Out carriage exemptions in the areas those exemptions apply they remove the need for you to have ADS-B Out so by definition there is no requirements specific to *those areas* that apply.

The regulatory issue is if you have a certified aircraft, regardless of where you intend to or actually fly it the install and equipment has to meet 2020 carriage mandate requirements. That brings in the requirements for a TSO-C145 GPS source (e.g. a TN70 not TN72), and other things like excludes using a Trig TT-21.

Darryl

On Friday, September 22, 2017 at 12:01:13 PM UTC-7, Darryl Ramm wrote:
On Friday, September 22, 2017 at 11:48:33 AM UTC-7, John Carlyle wrote:
Darryl,

You said "The TN72 does not meet TSO-C145 requirements (so can't be used for ADS-B Out in experimental aircraft where you want to use it to meet 2020 carriage requirements, in the case of gliders can't be used to meet requirements in the few areas where exemptions don't cover)."

For those of us who cannot keep up, would you kindly list the requirements where the exemptions don't cover?

Many thanks!
-John

John

Start thinking more like a lawyer. Since gliders have broad ADS-B Out carriage exemptions in the areas those exemptions apply they remove the need for you to have ADS-B Out so by definition there is no requirements specific to *those areas* that apply.

The regulatory issue is if you have a certified aircraft, regardless of where you intend to or actually fly it the install and equipment has to meet 2020 carriage mandate requirements. That brings in the requirements for a TSO-C145 GPS source (e.g. a TN70 not TN72), and other things like excludes using a Trig TT-21.

Darryl

14CFR 91.225 makes it mostly clear. Except I am hesitant to quote it again became it may yet again lead to lots of 10,000' confusion (just knock it off, gliders can operate above 10,000' without ADS-B Out).

But basically in a glider you can't fly without a compliant ADS-B out system in

Class B or C airspace, and

Anywhere below that top of Class B or Class C airspace or 10,000 feet MSL above that airspace, whichever is lower. Folks need to watch this, no clipping under or over (unless you are over 10,000' and above the airspace) corners of class B or C airspace.

This is the same as transponder requirements and you should really not be in those areas today without a transponder. Folks who fly gliders near controlled airspace should think about this.

And in all it's regulatory glory.... (yes OK gliders also need ADS-B Out in the Gulf of Mexico ADS-B surveillance area, if you out there in a sailplane you may have more problems than ADS-B Out compliance. But hey fly across the coastline in that area without a complaint ADS-B Out and you are violating 14CFR 91.225).


14CFR 91.225
....
(d) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft in the following airspace unless the aircraft has equipment installed that meets the requirements in paragraph (b) of this section:

(1) Class B and Class C airspace areas;

(2) Except as provided for in paragraph (e) of this section, within 30 nautical miles of an airport listed in appendix D, section 1 to this part from the surface upward to 10,000 feet MSL;

(3) Above the ceiling and within the lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL;

(4) Except as provided in paragraph (e) of this section, Class E airspace within the 48 contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the surface; and

(5) Class E airspace at and above 3,000 feet MSL over the Gulf of Mexico from the coastline of the United States out to 12 nautical miles.

(e) The requirements of paragraph (b) of this section do not apply to any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed, including balloons and gliders. These aircraft may conduct operations without ADS-B Out in the airspace specified in paragraphs (d)(2) and (d)(4) of this section. Operations authorized by this section must be conducted -

(1) Outside any Class B or Class C airspace area; and

(2) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport, or 10,000 feet MSL, whichever is lower.

Oh, Darryl - think like a lawyer? Can't - I'm a physicist, legal thinking "does not compute".

Many thanks for explaining, and then explaining even more in subsequent posts. Me and my experimental glider are going with a Trig TT22 and a TN 72...

-John

On Friday, September 22, 2017 at 3:01:13 PM UTC-4, Darryl Ramm wrote:
John

Start thinking more like a lawyer. Since gliders have broad ADS-B Out carriage exemptions in the areas those exemptions apply they remove the need for you to have ADS-B Out so by definition there is no requirements specific to *those areas* that apply.

The regulatory issue is if you have a certified aircraft, regardless of where you intend to or actually fly it the install and equipment has to meet 2020 carriage mandate requirements. That brings in the requirements for a TSO-C145 GPS source (e.g. a TN70 not TN72), and other things like excludes using a Trig TT-21.

Darryl

On Friday, September 22, 2017 at 4:21:56 PM UTC-4, John Carlyle wrote:
Oh, Darryl - think like a lawyer? Can't - I'm a physicist, legal thinking "does not compute".

- yeah, after all these years I still cannot make any sense of the wording "any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed". Had it said "nor" instead of "or", perhaps? (I do have a degree in physics.)

I asked Trig support this question:

"Will a TT21 + TN72 transmit a non-zero quality indicator?"

Here is their reply:

"The TT21 is fully certified to the latest ADS-B Out cert TSO C166b – so it can output all the required data. It is true that if you wish to meet ADS-B Out compliance FAR 91.227, you should have a higher power TT22. However, there is no way for the radar to tell if you’re using a TT21 or TT22. Inspection of your aircraft would be the only way to tell. As such I believe a number of experimental pilots have opted to ignore the requirement , but of course I cannot recommend this as it would be in violation of FAR 91.227 – the requirements for 2020 compliance.

The TN72 offers both a SIL =1 output, and also a SIL = 3 output. So this means that you can meet the FAA compliance check using your TN72 plus TT21. https://adsbperformance.faa.gov/PAPRRequest.aspx

If you so choose, you can opt to have your TT21 upgraded to a TT22. For more information on this please contact our US service centre below;

Trig Avionics Technical Support
9400 East 34th Street North
Wichita
KS 67226
United States

Tel: Toll Free 800 821 1212
Tel: +1 316 630 0101
Email:
Web: www.mcico.com
"

The response to my inquiry with is:

"The cost to update the TT21 to the TT22 is $950.00. Turn around time is 3-4 days in house."

Interesting that the information sent out from a 1090ES device doesn't
include enough to identify the model number. But of course an avionics
shop or A&P might spot the problem.



On 09/27/2017 11:24 AM, son_of_flubber wrote:
I asked Trig support this question:

"Will a TT21 + TN72 transmit a non-zero quality indicator?"

Here is their reply:

"The TT21 is fully certified to the latest ADS-B Out cert TSO C166b – so it can output all the required data. It is true that if you wish to meet ADS-B Out compliance FAR 91.227, you should have a higher power TT22. However, there is no way for the radar to tell if you’re using a TT21 or TT22. Inspection of your aircraft would be the only way to tell. As such I believe a number of experimental pilots have opted to ignore the requirement , but of course I cannot recommend this as it would be in violation of FAR 91.227 – the requirements for 2020 compliance.

The TN72 offers both a SIL =1 output, and also a SIL = 3 output. So this means that you can meet the FAA compliance check using your TN72 plus TT21. https://adsbperformance.faa.gov/PAPRRequest.aspx

If you so choose, you can opt to have your TT21 upgraded to a TT22. For more information on this please contact our US service centre below;

Trig Avionics Technical Support
9400 East 34th Street North
Wichita
KS 67226
United States

Tel: Toll Free 800 821 1212
Tel: +1 316 630 0101
Email:
Web: www.mcico.com
"

The response to my inquiry with is:

"The cost to update the TT21 to the TT22 is $950.00. Turn around time is 3-4 days in house."

On Wednesday, September 27, 2017 at 10:24:48 AM UTC-7, son_of_flubber wrote:
I asked Trig support this question:

"Will a TT21 + TN72 transmit a non-zero quality indicator?"

Here is their reply:

"The TT21 is fully certified to the latest ADS-B Out cert TSO C166b – so it can output all the required data. It is true that if you wish to meet ADS-B Out compliance FAR 91.227, you should have a higher power TT22. However, there is no way for the radar to tell if you’re using a TT21 or TT22. Inspection of your aircraft would be the only way to tell. As such I believe a number of experimental pilots have opted to ignore the requirement , but of course I cannot recommend this as it would be in violation of FAR 91.227 – the requirements for 2020 compliance.

The TN72 offers both a SIL =1 output, and also a SIL = 3 output. So this means that you can meet the FAA compliance check using your TN72 plus TT21. https://adsbperformance.faa.gov/PAPRRequest.aspx

If you so choose, you can opt to have your TT21 upgraded to a TT22. For more information on this please contact our US service centre below;

Trig Avionics Technical Support
9400 East 34th Street North
Wichita
KS 67226
United States

Tel: Toll Free 800 821 1212
Tel: +1 316 630 0101
Email:
Web: www.mcico.com
"

The response to my inquiry with is:

"The cost to update the TT21 to the TT22 is $950.00. Turn around time is 3-4 days in house."

That is some very useful information right there. Two questions:

Does the receiver (FAA) have any way to tell more information about the GPS source? If it is transmitting an SIL of 3 (required for carriage requirements), other than physical inspection can a receiver discriminate between a 70 and a 72?

What does Powerflarm do with a glider having both ADSB out and Flarm? Does it deambiguize?

Thanks for your patience.

On 9/22/2017 12:38 PM, Darryl Ramm wrote:
On Friday, September 22, 2017 at 9:11:34 AM UTC-7, Dan Marotta wrote:
This is very confusing.Â* So a TN72 is not a TSO device, but is compliant
and therefore can be mounted in an experimental aircraft which will be
seen by all compliant ADS-B In systems?Â* I feel cheated by having a
certificated aircraft!

On 9/21/2017 8:31 PM, Darryl Ramm wrote:
Walt, I think you are misunderstanding what Trig wrote. A TN72 GPS Source will be seen by everybody. That is why anybody doing ADS-B Out in an experimental glider with a TT22 should be equipping with at least a TN72 (or TN70, TN70 required for certified gliders).
--
Dan, 5J
You, and everybody else will continue to be confused if you keep talking about "TSO" and not specifying what TSO you are talking about. This caused lot of unneeded confusion and many posts on r.a.s. when the TN72 was announced. I don't know how many times I;ve already pointed this out.

The TN72 is a TSO-C199 Class B (aka TABS GPS source) device. Which from a regulation point of view makes no difference, since there are no installation or usage regulations that cover TSO-C199 devices. But since it is TSO-C199 we know important things about it's GPS quality, SIL parsameters, etc. and how it will interact with IFR GPS receivers and ground infrastructure.

The TN72 is Not TSO-C145 (requited for ADS-B Out in certified aircraft)

The TN72 does not meet TSO-C145 requirements (so can't be used for ADS-B Out in experimental aircraft where you want to us it to meet 2020 carriage requirements, in the case of gliders can't be used to meet requirements in the few areas where exemptions don't cover).

---

But yes I agree on the "feeling cheated" part in general, it points out the regulations are kinda stupid, especially when applied to gliders.

--
Dan, 5J