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Garmin GTN STC Approval Helicopters


Nomad110

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  • 1 month later...

Does anyone know the status on the Garmin GTN series STC approval for helicopters? We are looking to include both the 650 and 750 in an avionics upgrade in a EC-130 B4. I know there are already some aircraft with them installed. How do you think they got it passed?

 

Installed the GTN750 in my MD500 - did a field approval.

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Any updates on this? My local FAA examiner says they are no longer doing any field approvals for GTN products? Why do I feel like I'm the only helicopter without a GTN!

 

Nomad110 -

 

I know mine was done under a field approval but I also know that my G500H was not installed since they would not do that under field approval. I think each FAA office is different. The same office that did my 750 refused to do my TCAS, so I had it approved through a different FSDO.

 

I would not give up, just do a little shopping around to see who you can work with to get it done. Absent regional directives, I have learned that it is up to the local FSDO to make the call.

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Guest pokey

Just about all Field Approvals are gone these days...the FAA is getting closer and closer to reaching their goal of making general aviation a memory...

 

 

they lack the manpower and the funds, i do not believe this was "their" goal tho,,,,,,,,,,,much more $$ was needed to hang saddam,,, and if you believe that one? who wants to buy a bridge.

 

getting back on topic tho, if 'one' would 'share' their 337 with others,, would make another's FSDO maybe be more cooperative.. i have shared in the past (many years ago) & it sure made a difference,,, can't help you in this instance tho

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This is maybe a little crazy but what about designating the aircraft as experimental for the GTN installation and then simply remove the experimental status once the STC are in place? I don't use the aircraft for compensation or hire and it's only 91 but I wouldn't want to deal with any other restrictions like no class B or no night VFR...etc (not that those are in the FARs).

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If you don't need IFR, the information below may be helpful for aircraft under 6000 Lbs gross weight...

 

 

AC 20-138C Appendix 6

 

Installation of GNSS Equipment for VFR Use Only.

 

Introduction.

This appendix provides guidelines for the installation of stand-alone GNSS systems used for VFR navigation only.

 

General.

GNSS equipment may be installed on a no-hazard basis as a supplement to VFR navigation. Such installations need only to verify that the GNSS installation does not introduce a hazard to the aircraft (e.g., properly secured for crashworthiness, not combustible, etc) including EMI/EMC. Loss of or misleading VFR navigation information is considered a minor hazard failure condition; therefore, it is acceptable to have development assurance level D for software per RTCA/DO-178B, and electronic hardware, per RTCA/DO-254. A readable placard must be installed in clear view of the pilot stating that the equipment is only to be used for VFR operations, unless the equipment automatically displays this message on start-up and pilot action is required to clear the message. An AFMS/RFMS is not required since the placard or display contains the equipment limitation.

 

Applicability.

This appendix applies to all un-pressurized aircraft less than 6000 pounds where the modification is classified as a minor alteration.

 

GNSS

 

 

Global Navigation Satellite System

 

 

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This is maybe a little crazy but what about designating the aircraft as experimental for the GTN installation and then simply remove the experimental status once the STC are in place? I don't use the aircraft for compensation or hire and it's only 91 but I wouldn't want to deal with any other restrictions like no class B or no night VFR...etc (not that those are in the FARs).

Nomad110,

 

You can't just "switch" to experimental if it is a certified bird. You have to build at least 51% of it for it to be considered experimental. Rebuilding does not cut it.

 

There is one very rare exception and that is converting the aircraft for scientific research, however once it's converted it will be severely restricted and will never be able to be certified again.

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Nomad110,

 

You can't just "switch" to experimental if it is a certified bird. You have to build at least 51% of it for it to be considered experimental. Rebuilding does not cut it.

 

There is one very rare exception and that is converting the aircraft for scientific research, however once it's converted it will be severely restricted and will never be able to be certified again.

 

Thanks I clearly had no idea... I've never dealt with expiramental aircraft.

 

Anyway I give up...I'll just wait for the STC. I'll send my 430 in for the WASS upgrade so my G500H can work and just keep my old radio, transponder, and trusty NAT audio panel until the GTNs make their way. Thanks everyone for the creativity...

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MileHi480B, on 29 Apr 2013 - 21:23, said:

 

 

You can't just "switch" to experimental if it is a certified bird. You have to build at least 51% of it for it to be considered experimental. Rebuilding does not cut it.

 

There is one very rare exception and that is converting the aircraft for scientific research, however once it's converted it will be severely restricted and will never be able to be certified again.

Nomad110, on 29 Apr 2013 - 22:20, said:

 

Anyway I give up...I'll just wait for the STC.

 

That’s the best thing to do, “just wait for the STC.

 

The experimental changeover would only serve as a temporary fix. Moreover, in order to return the aircraft to standard category you would have to remove the GTN hardware, returning the aircraft to its original configuration, or wait and obtain the upcoming GTN STC then insure the hardware was installed per the STC.

 

The experimental category restrictions are under FAR 91.319 and FAR 21.191; however, you’ll still be able to switch back to standard category if you return the aircraft to its original configuration or obtain and comply with an STC for the equipment installed.

 

If shopping around FSDO’s for a field approval doesn't work, hire your own Designated Engineering Representative (DER). The DER will do the required engineering work for the FAA and submit Form 8110-3 (Statement of Compliance with Airworthiness Standards). The local FSDO is off the hook, your paper work is filed, and you can start installing your GTN hardware. This could cost as much as $6,000 or more.

 

They say one of the problems with the old field-approval was that some of the Airworthiness Inspectors at local FSDOs were approving items beyond their technical expertise and without technical backup. It was determined that specific engineering analysis ensures the highest of standards and safety. If you take a look at some of your old field-approvals, not much real analysis was done.

Edited by iChris
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Chris,

 

Based on your reputation here, I do not doubt what you say ... but after being involved in experimental aviation for 30-years you have told me something I did not know.

 

I ask this in an effort to learn more and not as a challenge ... but can you quote for me the FAR clause that actually says you can convert the aircraft back and forth?

 

Thanks!

Tom

 

 

The experimental category restrictions are under FAR 91.319 and FAR 21.191; however, you’ll still be able to switch back to standard category if you return the aircraft to its original configuration or obtain and comply with an STC for the equipment installed.

 

 

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Chris,

 

Based on your reputation here, I do not doubt what you say ... but after being involved in experimental aviation for 30-years you have told me something I did not know.

 

I ask this in an effort to learn more and not as a challenge ... but can you quote for me the FAR clause that actually says you can convert the aircraft back and forth?

 

Thanks!

Tom

 

 

 

When I was looking at putting in the G500H into my MD500, I had extensive discussions with the FSDO and Garmin about doing just that - placing my helicopter into experimental category, getting the work done enough that Garmin could use the info for an STC, and then switching it back. No one ever said it could not be done.

 

In fact, I think that is exactly what Corporate Helicopters did when they loaned their 500 to MD to get the TC for the G500H. It went into experimental and then back out once it was done according to the mechanics there.

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Yes ... you CAN convert a certified aircraft into an experimental aircraft for the purposes of Research and Development (and some other reasons See FAR 21.191) ... and that is one way to get STC approvals.

 

But you can get STC approval without that conversion ... so why go through all that trouble? Converting back to a standard certification means the aircraft conforms to ALL aspects of the original type certificate - in essence you would have to undue the changes you made or get an STC.

 

But the STC can be gotten without going "experimental".

 

So you may as well just get the field approval to begin with - make sense?

 

If you think for a minute that you can get a "new" standard airworthiness certificate for your own "altered" design and simply call it something "new" ... you are mistaken. The certification process takes hundreds of thousands of dollars not to mention the "intellectual property" problems you would have with the original manufacturer.

 

I have been restoring and building aircraft (certified and experimental) for 30-years. Never once do I recall anyone converting to experimental, then back to standard without either putting the aircraft back to its original condition or getting STC approval for all modifications.

 

Seems like a long way around for getting an STC.

Edited by MileHi480B
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Chris,

 

Based on your reputation here, I do not doubt what you say ... but after being involved in experimental aviation for 30-years you have told me something I did not know.

 

I ask this in an effort to learn more and not as a challenge ... but can you quote for me the FAR clause that actually says you can convert the aircraft back and forth?

 

Thanks!

Tom

 

 

 

When I was looking at putting in the G500H into my MD500, I had extensive discussions with the FSDO and Garmin about doing just that - placing my helicopter into experimental category, getting the work done enough that Garmin could use the info for an STC, and then switching it back. No one ever said it could not be done.

 

In fact, I think that is exactly what Corporate Helicopters did when they loaned their 500 to MD to get the TC for the G500H. It went into experimental and then back out once it was done according to the mechanics there.

 

The FAA issues a standard certificate when the Administrator finds that an aircraft conforms to its type certificate. The standard certificate is for the duration stated under § 21.181[a][1]. When you alter an aircraft in accordance with a proposed type design change, a flight test may be required to demonstrate compliance with airworthiness regulations.

 

A flight test also may be required if you wishes to conduct R&D testing of an altered aircraft. However, the altered aircraft is no longer in compliance with its type certificate; therefore, the aircraft does not have an effective airworthiness certificate under which to conduct the flight test. The aircraft’s standard certificate is effectively temporally suspended until the aircraft can be returned to service. In these cases an Application for Airworthiness Certificate (form 8130-6) can be submitted per § 21.193 and the FAA may issue a special airworthiness certificate in the experimental category under § 21.191[a] & for showing compliance with airworthiness regulations or for R&D flight-testing.

 

This is the key part: After flight-testing has been completed and the aircraft has been returned to its original configuration or the FAA approves the change in type design in writing (supplemental type certificate (STC), amended TC, FAA letter), form 8130-6 is submitted to reinstates the suspended standard certificate, under § 21.183[d].

 

REF:

§ 21.181[a][1]

§ 21.191[a] &

§ 21.193

FAA Order 8130.29A

Counsel Legal Interpretation, March 8, 2000

 

Office of Chief Counsel Legal Interpretation March 8, 2000

 

1. Section 21.18[a][1]) of Title 14, Code of Federal Regulations (14 CFR) states that a standard airworthiness certificate remains effective as long as maintenance, preventive maintenance, and alterations of the aircraft are performed in accordance with 14 CFR parts 43 and 91. Section 91.407[a][1] states that an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration may not be operated unless it has been approved for return to service by a person authorized under § 43.7, and the maintenance record entry required by § 43.9 or § 43.11 has been made. Therefore, a standard airworthiness certificate for an aircraft that has undergone alteration is not effective until the aircraft is returned to service in accordance with part 43.

 

2. When the applicant alters an aircraft in accordance with the proposed change in type design, a flight test of the altered aircraft may be required in order to show compliance with the applicable airworthiness requirements. If required, a successful flight test is necessary for the FAA to approve the applicant’s data. The flight test to show compliance is performed after alterations are made to the aircraft, but before the aircraft is returned to service; thus, there is no effective airworthiness certificate for the altered aircraft unless the FAA issues an experimental airworthiness certificate. The FAA issues that experimental certificate under § 21.191, Experimental certificates for showing compliance with regulations.

 

3. There is a difference between the flight test for showing compliance with regulations and the “operational flight check” required by § 91.407. Paragraph [a] of § 91.407 prohibits all persons from operating an altered aircraft prior to return to service; in contrast, paragraph addresses operation of the aircraft with passengers aboard. Thus, paragraph of § 91.407 is premised on the operator of the aircraft complying with paragraph [a], and the flight test required by paragraph is conducted after the aircraft is returned to service. After the aircraft is returned to service, the standard airworthiness certificate is effective, and there is no need for an experimental airworthiness certificate to be issued for the operational flight check.

Edited by iChris
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MileHi480B, on 29 Apr 2013 - 21:23, said:

 

There is one very rare exception and that is converting the aircraft for scientific research, however once it's converted it will be severely restricted and will never be able to be certified again.

 

 

Yes ... you CAN convert a certified aircraft into an experimental aircraft for the purposes of Research and Development (and some other reasons See FAR 21.191) ... and that is one way to get STC approvals.

 

 

I have been restoring and building aircraft (certified and experimental) for 30-years. Never once do I recall anyone converting to experimental, then back to standard without either putting the aircraft back to its original condition or getting STC approval for all modifications.

 

Seems like a long way around for getting an STC.

 

Maybe some misunderstanding. Again, I stated in my first post:

 

That’s the best thing to do, “just wait for the Garmin STC.

The experimental changeover would only serve as a temporary fix. Moreover, in order to return the aircraft to standard category you would have to remove the GTN hardware, returning the aircraft to its original configuration, or wait and obtain the upcoming GTN STC then insure the hardware was installed per the STC.

Edited by iChris
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Thanks Chris ... we were basically saying the same thing ... however you did it better.

 

In essence ... if you convert to experimental it is not a "short cut" to adding unapproved equipment. Either way, an STC must be gotten.

 

So my question ... wen Garmin, Aspen or any other manufacturer gets an STC for an entire fleet ... are they using an experimental aircraft? Or are they using computer models? Or something else. (I guess converting to experimental for the purposes of getting an STC for an entire fleet could be one of the few times this process is worth it.)

 

How do they do it?

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So my question ... wen Garmin, Aspen or any other manufacturer gets an STC for an entire fleet ... are they using an experimental aircraft? Or are they using computer models? Or something else. (I guess converting to experimental for the purposes of getting an STC for an entire fleet could be one of the few times this process is worth it.)

 

How do they do it?

 

The best way to evaluate new hardware for a standard category aircraft is in a standard category aircraft. To do that we must install the new hardware thereby altering the aircraft’s type design, which effectively suspends the aircraft’s standard airworthiness certificate until it is returned to its type design. Meanwhile, we can make application for a special airworthiness certificate in the experimental category so we can legally fly the aircraft and demonstrate compliance for a Supplemental Type Certificate (STC). Once the new hardware is STC approved, we can return the aircraft to service (with the new hardware) and submit form 8130-6 to reinstate the aircraft’s standard airworthiness certificate.

 

Most companies hire a Designated Engineering Representative (DER) to help them through this process. Whether or not the compliance with the certification basis can be demonstrated by analysis or by testing will depend on the scope of the STC. This is determined in the Compliance Planning phase were the FAA project team makes determinations on how to best demonstrate compliance.

 

The basic STC process:

 

The formal STC process begins by submitting the application form, Form 8110-12 (Application for Type Certificate, Production Certificate or Supplemental Type Certificate) along with cover letter and certification plan. The certification plan should contain detailed descriptions of the type design change, methods of compliance, how much and type of testing is necessary, when and where you will use designees (DER), and schedule information. The application is forwarded to FAA’s Aircraft Certification Office (ACO).

 

When the ACO accepts your STC application, they will establish a project and assign a project manager. After receiving the application and certification plan, the project manager will send you an acknowledgment. The acknowledgment and response will identify the project number, project manager and other members of the FAA certification team, including engineers, flight test personnel, Aircraft Evaluation Group (AEG) personnel, manufacturing inspection personnel, directorate project officer, and any other team members. The response will also indicate a date for a project initiation meeting. The number of people involved will depend on the scope of the STC. They’ll review your certification plan and if accepted, they will outline a program to demonstrating compliance with the certification basis by analysis and, if required, by testing.

 

The first task in the STC project is defining a certification basis. The certification basis is the set of rules that identify the airworthiness standards and other standards for which you must show compliance. You must demonstrate compliance with all elements of the certification basis before they issue an STC.

 

Compliance Planning - in this phase the FAA project team makes determinations on how to best demonstrate compliance with all elements of the certification basis.

 

Implementation Phase - FAA design evaluation, conformity inspections, applicant test plan and FAA plan approval, Experimental airworthiness certificate, engineering and flight tests, engineering certification tests, engineering compliance inspection, analysis, ground inspections, ground tests, and flight tests, and data submittal for approval.

 

Final steps- Review of applicant’s flight test results:

 

After the FAA compliance inspections and testing, you should submit all final data to the ACO project manager for review and approval. You must include items such as a flight manual supplement, test reports, or a list of life-limited parts, if any.

 

The ACO will evaluate the final data submittals for compliance with the certification basis. When they determine that the data demonstrates compliance, they’ll grant final approval of the modification or installation, and issue you an STC.

 

The complete certification basis will be included on FAA Form 8110-2.1 (the continuation sheets), unless it is identical to that shown on the TCDS of the TC product. They’ll then send you the STC, FAA Form 8110-2 and the continuation sheet, with a transmittal letter.

 

If, on your application form you indicated that the STC should be available for use by others, they also send a copy of the STC and FAA Form 8110-2 to the FAA STC database. This information is available to the public via the FAA web site at www.airweb.faa.gov/stc

Edited by iChris
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In essence ... if you convert to experimental it is not a "short cut" to adding unapproved equipment. Either way, an STC must be gotten.

 

 

Side Note: The FAA approves major changes in type design generally in writing in the form of a supplemental type certificate (STC), amended TC, or FAA letter. Therefore, approval may end with documentation other than an STC.

 

If shopping around FSDOs for a field approval doesn't work, hire your own Designated Engineering Representative (DER). The DER will do the required engineering work and complete Form 8110-3 (Statement of Compliance with Airworthiness Standards). Your paper work is filed, and you can start installing your GTN hardware.

 

Your form 337 would reference the engineering report filed with the Form 8110-3. The installation is for a single aircraft and if you chose not to apply for an STC, one will not be issued. This could be an option to take if Garmin abandon their efforts for an STC.

 

However, the STC path allows the option to obtain a Production Certificate:

 

21.119 Privileges.

The holder of a supplemental type certificate may—

[c] Obtain a production certificate in accordance with the requirements of subpart G of this part for the change in the type design approved by the supplemental type certificate.

 

21.120 Responsibility of supplemental type certificate holders to provide written permission for alterations.

A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA.

 

21.132 Eligibility.

Any person may apply for a production certificate if that person holds, for the product concerned

[a] A current type certificate,

A supplemental type certificate, or

[c] Rights to the benefits of that type certificate or supplemental type certificate under a licensing agreement.

Edited by iChris
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Chris,

 

A question ... when a company like Garmin or any other after-market manufacturer wants to get a blanket STC for a fleet ... how do they do it? Do they convert to experimental while testing is going on? Or do they do it another way?

 

Seems like a catch-22 if they don't use an experimental certificate (for R & D), then they are technically breaking FARs, right?

 

Tom

 

P.S. - SORRY! JUST SAW THAT YOU ACTUALLY ANSWERED ME ALREADY!

Edited by MileHi480B
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