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Impossible to Believe. but...

Printed From: Avidyne
Category: Avidyne General
Forum Name: DFC90/DFC100 Digital Autopilot
Forum Description: Topics on the Avidyne DFC Digital Autopilots
Printed Date: 20 Apr 2019 at 10:48am
Software Version: Web Wiz Forums 12.01 -

Topic: Impossible to Believe. but...
Posted By: ddgates
Subject: Impossible to Believe. but...
Date Posted: 05 May 2016 at 12:01pm
Does the newly articulated NORSEE policy apply to the DFC90?

It mentions AOA as expected, attitude indicators, but also TAWS and Autopilots.

Excerpted from FAA policy statement:

Equipment approved as NORSEE has a variety of uses including—
1. Increasing overall situation awareness;
2. Providing additional information other than the aircraft primary system;
3. Providing independent warning, cautionary, or advisory indications; and
4. Providing additional occupant safety protection.
Most NORSEE categories fall under the avionics, electronic instrument, and display categories. However, mechanical and other NORSEE categories can use the same methodology and evaluation approach, as outlined in this policy statement. The types of equipment that may be considered NORSEE include, but are not limited to the following:
 Traffic advisory system,
 Terrain advisory (such as a terrain awareness and warning system (TAWS)),
 Attitude indicator,
 Weather advisory,
 Crashworthiness improvement,
 Configuration advisory (such as gear advisory for floats and takeoff/landing configuration),
 Supplemental indication (such as a fuel flow or fuel quantity indicator),
 Monitoring/detection system (such as a smoke, carbon monoxide, or fire detector),
 Extinguishing system (such as a fire extinguisher), and
Stability and control (such as an autopilot or stability augmentation system).
The goal is to establish one policy that is scalable and adjustable to accommodate and encourage the installation of new technology safety enhancements into all aircraft product types

I find it impossible to believe, but this is what the document says.

I couldn't find a mode to upload or link the entire document.

EDIT:  Here's a link.

Please enter my order today....

David Gates

Posted By: Catani
Date Posted: 05 May 2016 at 4:48pm
The FAA has and continues to make some amazing changes in the past couple of years, from a much less punitive enforcement policy, to a new Part 23 requiring dramatically less FAA involvement, to allowing AOAs to be put on aircraft without an STC, to the dramatic Dynon-Cessna announcement at Sun n Fun last month.  And with NORSEE, it seems the FAA is taking it to an entirely new level of deregulation.  Manufacturers like Avidyne are going to have to submit some backup paperwork - not just any jaybird is going to be able to put a homemade toaster in any aircraft on his own initiative and say-so.  That will take some time for manufacturers to re-orient their approach with the FAA, but it does seem the DFC90 along with a lot of other stuff will not be needing STCs or AMLs anymore, once the new backup documentation is sent in to the FAA.  Remarkable changes indeed.

Posted By: ddgates
Date Posted: 05 May 2016 at 4:51pm
I'd bet that FAA blocks autopilots as saying their failure mode is not trivial....

But what do I know?

David Gates

Posted By: Catani
Date Posted: 05 May 2016 at 6:13pm
Originally posted by ddgates ddgates wrote:

I'd bet that FAA blocks autopilots as saying their failure mode is not trivial....

Since autopilots were specifically mentioned in the new NORSEE policy document as devices benefiting from the new policy, that bet is probably not a good one IMHO.  Even now, autopilots are not required for Part 91 IFR or VFR operations, and if inop can be placarded and you're good to go into WOXOF and hand fly if that suits you.  My guess is that's going to be the new standard for whether things must be certified in certified aircraft: are the components required by FARs for the planned flight?  If not, why certify them if the manufacturer stands behind the optional devices? If they break in flight, turn them off and proceed on - they are not required for flight, no need for lifetime MTBFs for items you're not even required to have on board. This is one of many amazing changes of attitude at the FAA, as I see it.  It will take manufacturers time to digest and react to.  Slow ones might miss out on market share.

Posted By: ddgates
Date Posted: 05 May 2016 at 9:28pm
I hope you are right.

A runaway trim servo is not a trivial event and could be considered a failure mode; not as simple as placarding inop.

A lot of us in GA want to believe that there could be a newer and friendlier FAA, just haven't seen it in my 26 years of flying.

I do agree with you that if this is the way to the promised land, manufacturers will want to get on board sooner rather than later.

At the same time, the price reductions which should follow from this may not be attractive to the Genesys, Cobhams, etc of the aviation world.

David Gates

Posted By: paulr
Date Posted: 06 May 2016 at 11:40am


Posted By: Catani
Date Posted: 06 May 2016 at 3:33pm
Originally posted by ddgates ddgates wrote:

I hope you are right.

A runaway trim servo is not a trivial event and could be considered a failure mode; not as simple as placarding inop.

That's covered under Section 2 of the NORSEE policy, providing a clear path to approval if the design incorporates devices to minimize the harm (i.e., trim disconnect buttons for example).

The test for a NORSEE device is in the first sentence of the new policy: (1) it must not be required equipment (see Part 91, Subpart C), and (2) it increases safety.  Surely, an autopilot fits those two requirements.  Later, the policy states the idea is that the increased safety the device affords offsets the risk of bypassing traditional certification requirements, so it's a net positive - like AOA indicators.  Finally, the policy makes clear the FAA has a role to play in reviewing the documentation submitted by the manufacturer that backs up its claims that the product is safe and effective - a higher standard than TV makers have to adhere to.  And the upstart ABC Carpentry & Autopilot Shop is not going to be able to market its new Flash Gordon Model 101 Autopilot made from used Chevy parts for use in certified aircraft without FAA approval under this new NORSEE policy.

Posted By: ddgates
Date Posted: 06 May 2016 at 4:03pm
Bring it on!

David Gates

Posted By: AviJake
Date Posted: 07 May 2016 at 4:16pm
You guys are sort of correct.  We've been spending a LOT of  time talking with various parts of FAA, EASA, EAA, GAMA and others on the topic trying to understand the evolving positions.

The FAA continues to tell us there are many more hurdles to jump over than what the public is being led to believe.   We have encouraged EAA to clarify for the public what their recent STC really allows and how it was achieved.   It was definite progress for sure but will not result in overnight revolutionary changes.  Anyone who expects that is not grounded in reality.

By no means do I mean to sound like Debbie Downer on this.  There are some very cool sea changes in play right now.  It is not clear how they will benefit the Avidyne's and Aspens and Garmins of the world but they will definitely help out the end user customer.  Some will come quickly (like this summer) and some will take much longer.  I'm sure no one, anywhere, really knows how far we'll be able to take this.

On the autopilot question specifically, we've been working for some time with the FAA to create an AML STC path for autopilots. I'm sure other vendors are doing the same and I'm also sure the FAA was thinking about this and searching for a path even without the prodding of Avidyne and others.   The FAA is confident they will find a way to enable AML STCs for autopilots.  The key will be how much longer this will take.  But whether it's publicly viewable optics or not, it should NOT give anyone the impression that there aren't a lot of smart and dedicated folks in government and private industry working to provide just that.

Steve Jacobson

Posted By: ddgates
Date Posted: 07 May 2016 at 5:08pm
Excellent context, thank you.

The policy is announced, but the devil is in the implementation.

David Gates

Posted By: ChuckGell
Date Posted: 07 Oct 2016 at 4:57pm
The Baron pilots are losing hope!

Chuck Gell

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