Backcountry Pilot • CAR3 VS TSO’d avionics.

CAR3 VS TSO’d avionics.

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Re: CAR3 VS TSO’d avionics.

I'm glad we are having this debate.

In reality there needs to be "Approved Data" in the FAA eyes.

Are we saying that experimental Avionics have Zero data or testing?

My thought is even experimental avionics are more accurate than CAR3 1946


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Re: CAR3 VS TSO’d avionics.

"Approved Data" or TSO, or whatever isn't really the issue. The REAL issue is the FAA and it's singular inconsistency in interpreting the regulations,policies, etc. And, it's NOT a safety issue. Good grief, we have had how many thousands of planes running around with field approvals for decades and you hardly ever hear of an issue from those.

But, try to get someone to issue a field approval these days. Every FSDO is different, but the primary response is that it's a lot easier to say NO than to work it out. And, this seems to be true of Engineering as well.

Meantime, our maintenance professionals put their signature, which means their certificate, on the line every time they sign something, ANYthing off. What if the next mechanic decides your plane isn't legal, just cause Joe AI thought that was a "Minor", and the new guy disagrees. The point being, mechanics are just as inconsistent as the FAA, wonder why?

There are indeed cases where the regulations and policies APPEAR to be straightforward, but there are too many Philidelphia lawyers out there.

I once wanted to put a set of German wheel skis on a Husky. These were JAA certified. Turns out the FAA jointly approves most JAA approved stuff. So, no sweat, right? Nope. I finally wound up talking to the head of the Denver Aircraft Certification Office. He informed me that, with JAA approval, we could install the skis, BUT, they'd have to be signed off on a 337 by an IA AND a FSDO Inspector. I asked why a FSDO type, since they are approved, AND STC'd. His response: "That's the way it is.".

Fortunately, we found a very cooperative FSDO Inspector, who signed them off.....he was just as confused why he needed to sign them off as I was.....so took some convincing.

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Re: CAR3 VS TSO’d avionics.

mtv wrote:"...... But, try to get someone to issue a field approval these days. Every FSDO is different, but the primary response is that it's a lot easier to say NO than to work it out. And, this seems to be true of Engineering as well. ....


What he said.
I was able to get a FA for 26" GY's....but it took 11 months & a lot of back & forth. Ridiculous.
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Re: CAR3 VS TSO’d avionics.

I've had good luck with the Portland FSDO. I'm 3 for 3 on the PA-22, the last one being a propeller field approval that had to go through the Seattle ACO.

2 were follow-ons and one used two existing STCs to make the case for interpolation. Those guys follow one singular rule: CYA. No one will stick their neck out for you with their signature. Precedent and data is key.
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Re: CAR3 VS TSO’d avionics.

Zzz wrote:I've had good luck with the Portland FSDO. I'm 3 for 3 on the PA-22, the last one being a propeller field approval that had to go through the Seattle ACO.

2 were follow-ons and one used two existing STCs to make the case for interpolation. Those guys follow one singular rule: CYA. No one will stick their neck out for you with their signature. Precedent and data is key.


True, but now take that plane to a different jurisdiction......

I ran a Cub in Minnesota, the the airplane (leased) was registered in North Dakota. With the owners permission, we got a field approval from the Minneapolis FSDO to install telemetry antennas.

A few months later, a Fargo FSDO Inspector visited our airport and yellow tagged the airplane as unairworthy, because of the antennas. We took the tag off and flew the plane. The ND and MN FSDOs had a long argument on the subject, the ND guy claiming antennas could not be field approved on standard category aircraft. MN said you could. Was finally settled by the Regional Administrator telling the FSDO folks to stay on their own side of the Red River. Problem solved? Hardly.

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Re: CAR3 VS TSO’d avionics.

mtv wrote:
Zzz wrote:I've had good luck with the Portland FSDO. I'm 3 for 3 on the PA-22, the last one being a propeller field approval that had to go through the Seattle ACO.

2 were follow-ons and one used two existing STCs to make the case for interpolation. Those guys follow one singular rule: CYA. No one will stick their neck out for you with their signature. Precedent and data is key.


True, but now take that plane to a different jurisdiction......

I ran a Cub in Minnesota, the the airplane (leased) was registered in North Dakota. With the owners permission, we got a field approval from the Minneapolis FSDO to install telemetry antennas.

A few months later, a Fargo FSDO Inspector visited our airport and yellow tagged the airplane as unairworthy, because of the antennas. We took the tag off and flew the plane. The ND and MN FSDOs had a long argument on the subject, the ND guy claiming antennas could not be field approved on standard category aircraft. MN said you could. Was finally settled by the Regional Administrator telling the FSDO folks to stay on their own side of the Red River. Problem solved? Hardly.

MTV
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Re: CAR3 VS TSO’d avionics.

mtv wrote:
True, but now take that plane to a different jurisdiction......

I ran a Cub in Minnesota, the the airplane (leased) was registered in North Dakota. With the owners permission, we got a field approval from the Minneapolis FSDO to install telemetry antennas.

A few months later, a Fargo FSDO Inspector visited our airport and yellow tagged the airplane as unairworthy, because of the antennas. We took the tag off and flew the plane. The ND and MN FSDOs had a long argument on the subject, the ND guy claiming antennas could not be field approved on standard category aircraft. MN said you could. Was finally settled by the Regional Administrator telling the FSDO folks to stay on their own side of the Red River. Problem solved? Hardly.

MTV

And that's EXACTLY why I'm staying on the Experimental side...
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Re: CAR3 VS TSO’d avionics.

JP256 wrote:
mtv wrote:
True, but now take that plane to a different jurisdiction......

I ran a Cub in Minnesota, the the airplane (leased) was registered in North Dakota. With the owners permission, we got a field approval from the Minneapolis FSDO to install telemetry antennas.

A few months later, a Fargo FSDO Inspector visited our airport and yellow tagged the airplane as unairworthy, because of the antennas. We took the tag off and flew the plane. The ND and MN FSDOs had a long argument on the subject, the ND guy claiming antennas could not be field approved on standard category aircraft. MN said you could. Was finally settled by the Regional Administrator telling the FSDO folks to stay on their own side of the Red River. Problem solved? Hardly.

MTV

And that's EXACTLY why I'm staying on the Experimental side...


I don't have that choice


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Re: CAR3 VS TSO’d avionics.

lownslow79 wrote: <snip>
See This great explanatory article written by VAL AVIONICS https://www.valavionics.com/installation-in-type-certificated-aircraft.html

This morning I came across an interesting sidebar to the preceding article: https://www.faa.gov/aircraft/safety/programs/sups/upn/media/2018/S20180315005_UPN.pdf
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Re: CAR3 VS TSO’d avionics.

iPat wrote:
lownslow79 wrote: <snip>
See This great explanatory article written by VAL AVIONICS https://www.valavionics.com/installation-in-type-certificated-aircraft.html

This morning I came across an interesting sidebar to the preceding article: https://www.faa.gov/aircraft/safety/programs/sups/upn/media/2018/S20180315005_UPN.pdf


Wow, that's crazy. First time I've ever seen a "F this company at this address and these products of theirs in particular" advisory from the FAA. Unless you count ADs I guess.
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Re: CAR3 VS TSO’d avionics.

We’re from the government, and we’re here to help.
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Re: CAR3 VS TSO’d avionics.

J3cubcapt wrote:I have a Stinson 108-1 that I'm restoring from the ground up. I have to completely rebuild the dash anyway so I want modern glass instruments.

I think its CRAZY that I have to pay $6100 MORE for the "Certified" version of the Garmin 3X touch over the Experimental which we all know are the exact same equipment.

You KNOW the Experimental version is still FAR exceeding the CAR3 3.663 requirements.


I see where you are coming from and have both experimental G3X and type certificated G3X systems installed in different aircraft. But as to your "$6100 MORE" statement please understand the difference is actually quite a bit less. Why? Because Garmin sells the experimental GDU bare bones without any LRUs or connector kits etc. But the type certificated item comes with those accessories as the FAA wants the required parts kitted as part of the STC. So by the time you put all the same pieces together in an Experimental installation the difference is more on the order of $800, not $6100. Still nothing to sneeze at but I wouldn't want any fellow EAB owner to wonder why it cost them almost as much for the equipment as the type certificated version.
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Re: CAR3 VS TSO’d avionics.

jliltd wrote:
J3cubcapt wrote:I have a Stinson 108-1 that I'm restoring from the ground up. I have to completely rebuild the dash anyway so I want modern glass instruments.

I think its CRAZY that I have to pay $6100 MORE for the "Certified" version of the Garmin 3X touch over the Experimental which we all know are the exact same equipment.

You KNOW the Experimental version is still FAR exceeding the CAR3 3.663 requirements.


I see where you are coming from and have both experimental G3X and type certificated G3X systems installed in different aircraft. But as to your "$6100 MORE" statement please understand the difference is actually quite a bit less. Why? Because Garmin sells the experimental GDU bare bones without any LRUs or connector kits etc. But the type certificated item comes with those accessories as the FAA wants the required parts kitted as part of the STC. So by the time you put all the same pieces together in an Experimental installation the difference is more on the order of $800, not $6100. Still nothing to sneeze at but I wouldn't want any fellow EAB owner to wonder why it cost them almost as much for the equipment as the type certificated version.


As far s the raw equipment is concerned, you may be right on price. However, Garmin still gets way more money for the certified version since the installation of the certified G3X is required to be done by a Garmin Dealership. That installation alone could easily cost well north of 10k, where the experimental version could be installed by whoever the builder is. Lots of great shops out there that sell pre-made wiring harnesses that make installation by any A&P a breeze, but us certified folks are bound to the expensive garmin shops for our installations.
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