Self Exchange of IFD540s and 440s

We recently read an online story in the aviation ePubs of the world (page 22 of the April 2016 edition of Aviation Consumer) where the author talked about using CFAR14 Part 43.3 and Part 43 Appendix A Preventative Maintenance as perhaps a means to help lower the overall cost of avionics and thought that was an interesting idea.

So we did some homework including running it by the FAA and concluded it was a viable approach and then produced an IFD-series navigator self-exchange guide the provides step-by-step instructions on how to do this.   The document starts with a 10-step test that determines if you and your airplane meet the qualifications to take advantage of this process.

If you pass those 10 criteria questions, then the rest of the document provides explicit instructions on how to accomplish the process and make the appropriate log book entries.

The document can be downloaded at:  http://www.avidyne.com/support/doctype.asp?doctype=installation+manual&list=doc

Is there anyone out there who meets the criteria and is interested in trying this out?  We would be quite interested in hearing feedback and be on-call for the effort.  We suspect this will appeal to a small segment of folks and may be controversial in other areas - we are not trying to stir up any trouble but hope to provide this as a tool to help manage the cost of avionics upgrades.

The guide is intended to instruct aircraft owners how to replace a Garmin GNS430(W)/530(W) with an Avidyne IFD440 or IFD540.  It must be a true plug & play installation meaning you can not use it to go from non-WAAS to WAAS or add any more wiring or parts.

For reference, I've included the 10 qualification criteria below:

If you can answer “Yes” (or directed to skip the question) to each of the questions below, then you are permitted to perform this exchange on your own in accordance with CFAR 14 Part 43.3 and Part 43 Appendix A.

If you answer “No” or “I don’t know” to any of these questions/tests then it is unlikely you are permitted to perform this exchange on your own and you should consult an approved installation shop.  Avidyne Customer Support can supply the list of approved installation shops, if needed.

 

 

1	Are you a holder of a United States pilot certificate?	Yes	No
2	Do you own or operate the aircraft (fixed wing or rotary wing) in question and is it registered in the US (N-reg)?	Yes	No
3	Can you confirm the aircraft in question is NOT operated under CFAR 14 Part 121 (Air Carrier), 129 (Foreign Air Carrier) or 135 (Commuter or On-Demand Operations)?	Yes	No
4	The Garmin unit that you want to replace with an Avidyne IFD4XX or IFD5XX unit satisfies one of the acceptable combinations in the table immediately below these questions?	Yes	No
5	Can you confirm the Garmin unit being replaced does NOT currently have a TAWS (fixed wing) or HTAWS (rotary wing) capability? Note: this can be determined by turning on the Garmin and noting if the TAWS system in displayed on the start up screens.	Yes	No
6	If you are replacing a WAAS-capable Garmin unit (e.g. GPS 400W, GNS 430W, GPS 500W, GNS 530W) then you can skip this question. Can you confirm that the aircraft is question does NOT have a Garmin GA56 GPS antenna (Part # 010-10040-01 or 011-00134-00) connected to the unit to be replaced? Note:  GA56W and GA56A antennas are perfectly acceptable.	Yes	No
7	If your Garmin unit is powered by 28VDC, then you can skip this question. If you are replacing a GPS400(W) with an IFD410 or replacing a GPS500(W) with an IFD510 then you can skip this question. Can you confirm that electrical bus that the IFD will be connected to is either a 28V ± 3V system OR that if it is connected to a 14V ± 3V system, then the circuit breakers guarding the IFD unit are at least 7.5 A?	Yes	No
8	Can you confirm that to the best of your knowledge, there are no known installation problems (e.g. bent pins, inability to seat in the tray, etc) with the Garmin unit  you intend to replace and that it works well enough to record the configuration settings in it?	Yes	No
9	Do you have a 3/32” allen wrench available? Note:  There should have been a proper allen wrench included with the IFD unit.	Yes	No
10	Do you have the aircraft log books available?	Yes	No

Edited by AviJake - 09 May 2016 at 7:46pm

We think that might be correct if folks elect to do this on their own and then the next time they're in the shop, they elect to add some of the optional wiring that requires an avionics shop for most folks (like adding wiring to that audio panel to hear the aurals).  We'll see.

okay, good point

How would this meet the STC requirement to have a 337 form signed off by an A&P/IA and submitted to the FAA?

sounds like this could be the basis of a 540 - 550 exchange program......

chflyer wrote: How would this meet the STC requirement to have a 337 form signed off by an A&P/IA and submitted to the FAA?

There is no STC involved in this activity.  This is a preventative maintenance action.

tony wrote: sounds like this could be the basis of a 540 - 550 exchange program......

Steve,

I know it seems like a great idea, but as an A&P and IA, I have some experience here.  The core problem is this:
The action being performed is not preventive maintenance.  It is an alteration to the aircraft (albeit a minor one).  The aircraft's Equipment List must be revised to indicate the new inventory of components.

Alterations are not within the authority of a Pilot.  (Pilots should not be revising the Equipment List.)  One must at least be the holder of an Airframe Mechanic license to perform a minor alteration on an airframe.

In the FAA's regulatory world, there are five "kinds of things" that can happen to an airplane, and these things are covered under different sections of the FARs and may be performed by individuals of increasing levels of certification:
1) Preventive Maintenance
2) Maintenance
3) Alteration (Minor & Major)
4) Repair (Minor & Major)
5) Inspections

Changing from a 530 to a 540 is in bucket #3, not bucket #1.

+++++++++++++++++++++++++++++

That said, I have two comments:
I would be interested in seeing the table referenced in question #4.
Question #7 seems self-contradictory.  If the Garmin was 28 volts, then you skip the question.  So why is a 28 volt condition part of the question?

David Bunin

AviJake wrote: With question #7, by definition, the 28V aircraft already come with the proper amperage circuit breaker so those owners don't even need to think about that issue.

Okay, I understand and that makes sense.  The question is really only for owners of 14v airplanes.

So then why is "28v+/-3" one of the conditional answers?  Nobody is going to have that voltage in a 14v airplane.

It might be clearer to just ask if the circuit breaker is rated for at least 7.5 amps in a 14v installation.

David Bunin

BTW, here's a snippet from the Exchange Manual that cites the FAR basis that formed the core of the argument for anyone interested:

This section contains snippets of the relevant portions of 14 CFR Part 43 that serve as the regulatory basis for this exchange process.

 

14CFR Part 43 describes aircraft maintenance, preventive maintenance, rebuilding and alteration.

 

Sec. 43.3  
Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of appendix A of this part.

 

Major alterations, Major Repairs and Preventive maintenance are described in 14CFR Part 43 Appendix A.

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, an operational check must be performed in accordance with the applicable sections of part 91 of this chapter.

Edited by AviJake - 12 May 2016 at 8:34am

HQ FAA/AFS (Flight Standards) is "the FAA" who are fine with it.  Not sure you can do much better than that.

It's akin to what TKM is doing for the owner replacement of BK-175 Nav/Coms.

We also include the log book sticker (and extraction tool) in the ship kit for those who want to give this a shot.

David's approach sounds like a good belt & suspenders approach for those who still aren't comfortable on their own.  I would agree this is not for everyone but for some folks, I think this is an awesome option.

What about software updates?  Is that something that will ever be available at the user level or is the process too fraught with the possibility of bricking the unit?

I replace firmware on computer components all the time and very rarely turn one into a door stop.  Actually, it's been years since that has happened.  I don't know if the hardware has gotten more bullet proof or the firmware has gotten that much better.

That is an interesting paradox.

I do find it weird that the FAA has agreed that replacing a navigation/communication system with a different (and BETTER) navigation/communication system is not an alteration, but they balk at software loading on an existing system (which the pilot does every 28 days).  The new software is an alteration, but the new hardware with the new software isn't?  They aren't bothered that the IFD-540 does not share any software with the GNS530W?

Remember, I am a supporter.  I want this to work out for everybody.

Here is another detail: the flight manual supplement.
If your airplane has an Approved Flight Manual (AFM) then the navigation system pages are an Approved Flight Manual Supplement (AFMS).  To remove the Garmin AFMS and insert the Avidyjne AFMS is a change to approved data (the AFM).  That is the piece that usually puts this into the realm of major alteration, and the reason for a 337 and the involvement of an IA.

The slide-in Nav/Com radios from TKM do not encounter this stumbling block because most of those older planes did not have an AFM.

David Bunin

I do find it weird that the FAA has agreed that replacing a navigation/communication system with a different (and BETTER) navigation/communication system is not an alteration, but they balk at software loading on an existing system (which the pilot does every 28 days).  The new software is an alteration, but the new hardware with the new software isn't?  They aren't bothered that the IFD-540 does not share any software with the GNS530W?

As I was saying on another thread in this forum, I worked for the FAA for 27 years and I never did figure them out. I was most suprised to see the approval of the Dynon DA-10 for certified aircraft.  That seemed to fly right into the limelight.  Most of the stuff the FAA does is akin to watching paint dry.  Actually, since paint does actually dry, that statement is not fair to paint.

You are correct in that we already do updates when we load the Jeppesen data every 28 days.  It's not like it's rocket surgery.  They send detailed instructions that would put some microwave tv dinner instructions to shame.

I've had firmware updates on computer hardware that came with no instructions and you were left to figure it out on your own.  One wrong move and "Brick".

I certainly wouldn't mind doing it myself as long as I was able to talk to someone if there was an issue and not give me a lot of attitude if something did turn it into a toaster.