On June 11, Aircraft Electronics Association President Paula Derks testified before the U.S. House Committee on Small Business hearing titled, "Federal Aviation Administration's 2020 NextGen Mandate: Benefits and Challenges for General Aviation."
Following the association's congressional testimony, David Loso, chairman of the AEA's board of directors; Derks; and Ric Peri, AEA vice president of government and industry affairs, met with Michael Whitaker, FAA deputy administrator and chief NextGen officer; John Hickey, deputy associate administrator for aviation safety; and John Duncan, director, Flight Standards Service, regarding ADS-B implementation and the challenges of NextGen.
While there were a number of issues discussed and the AEA will be facilitating more discussions in the future, one of the most significant items of interest discussed was that, as emphasized by Hickey, Field Approvals are a viable approval mechanism for ADS-B "in all aircraft types and categories."
According to the FAA's October 10, 2012, memorandum included as part of the latest version of the FAA's field approval job aid regarding ADS-B installations for ALL aircraft categories, "ADS-B Out systems can be approved using data approvals other than an STC if all of the following conditions are met:"
- The ADS-B Out equipment is authorized under TSO-C166b or TSO-C154c.
- The GNSS position sensor is approved under TSO-C129 or later, TSO-C145a/C146a or later, or TSO-C196 or later.
- The ADS-B Out equipment (transponder or universal access transceiver), GNSS position sensor, and interconnect wiring are identical to previously-approved design under type certificate or supplemental type certificate.
- The installation is performed in accordance with the equipment manufacturer's installation guidance.
- The installer verifies the installation in accordance with the guidance of AC 20-165, Chapter 3 and 4. The data from the previously-approved installation may be used to address paragraphs 3-1 c, 3-1 d, 3-3 b (2), 4-1 b, 4-1 c. A return to service operational check in accordance with AC 20-165 Section 4-3 is recommended for determining if the installation performance is acceptable.
All other aspects of the installation qualify for installation under 14 CFR Part 43 and follow guidance in the Major Alteration Data Approval Job Aid (8900.1 Fig 4-68 or other approved guidance).
When field approvals are granted for qualifying ADS-B Out projects, approval of an AFM supplement with the following statement is delegated to the approving ASI:"The installed ADS-B Out system has been shown to meet the equipment requirements of 14 CFR §91.227."
The AEA appreciates that this policy is in place; however, although it is nearly 2 years old, the industry continues to struggle with obtaining any type of approval other than STCs. Additionally, the policy restraints on some of the GNSS approvals might significantly affect the ability to fully utilize this ADS-B approval policy.
To assist the agency in the implementation of this critically important approval mechanism, the AEA has committed to quarterly reporting the volume of ADS-B field approvals. Therefore, the AEA membership is requested to report, via email, each ADS-B field approval (or DER/ODA approval) application and the success or failure of the application to the AEA at the contact information below. Please include any justification for the failure of obtaining an ADS-B field approval.
Please note: Cross-category aircraft approvals (i.e. Part 23 to Part 27) are eligible for field approval. The criteria are that (1) the ADS-B Out system has been previously approved; and (2) the subsequent installation is identical to the TC/STC approval. Notwithstanding the possibility of other system approvals affecting the eligibility, the ADS-B system is a candidate for a field approval.
Previously approved systems can be found on the AEA's NextGen website at www.aea.net/NextGen.
To help streamline field approvals for ADS-B installations, please email the following information to Ric Peri at email@example.com.Report each ADS-B field approval (or DER/ODA approval) application and the success or failure of the application. Please be brief. Please include any justification for the failure of obtaining an ADS-B field approval.
FOR MORE INFORMATION:
Contact Ric Peri, AEA vice president of government and industry affairs, by email at firstname.lastname@example.org or by phone at 202-589-1144.