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All eyes on a gentler part 23.

As much as there is to like about Dynon's SkyView Touch, the buzz kill is that the non-TSO system is off limits to existing Part 23 certified aircraft. In our view, it's an outdated limitation that might have little if any bearing on system reliability and safety.

Since regulation and better judgment restricts VFR-only LSAs from flying in instrument conditions, their avionics shouldn't be used for sole means primary navigation. In the eyes of the FAA, this limitation is supposed to curtail the risk factor should the system fail at the worst time. But IFR-equipped experimental aircraft regularly fly in instrument conditions, and have so for years with non-certified equipment leading the way. Pilots of experimentals accept the perceived risks that tag along with non-certified status. Without statistics, it's impossible to know if new, non-Beta, non-certified systems like Dynon's SkyView Touch and Garmin's 63X Touch will increase the risk of crashing because they don't have a TSO, but we suspect they won't.

In many ways, Dynon's SkyView Touch has more failsafe than many certified retrofit avionics. One of the areas that the FAA is concerned with is the system's interaction with the aircraft electrical bus. But Dynon's data and power path design helps ensure that one critical failure won't take down the entire system. There's also the backup battery.

But one area that's worth considering is DO-178B software certification guidance, and Design Assurance Level. In certified equipment, this TSO-governed criteria addresses various potential failures of the software and the outcome it might have on the flight, from no effect to catastrophic. This software standard might not exist in uncertified equipment.

By now you've probably heard about the ARC's (Aviation Rulemaking Committee) proposal to the FAA that could relax the certification standards for some light aircraft. How the revised rules will read, and whether it will affect aftermarket avionics retrofits and the requirement for TSO is unknown. The FAA already announced it would miss the December 2015 deadline.

The age-old standard is that an aircraft's initial type certificate has the final say over which equipment can be installed. Flight Design is currently certifying its C4 composite single under Part 23 regulations, but is boldly attempting certification with Garmin's non-TS0d G3X Touch. The system is such an integral part of the aircraft, it even has its own name--Flight Design Vision Touch by Garmin. That's the C4 Vision Touch cockpit in the photo below.

Flight Design says it can get away with Garmin's uncertified equipment because the proposed changes to Part 23 has a provision for use of non-TSO equipment when blanketed under the aircraft's type certificate. For IFR eligibility and functionality, the Vision Touch interfaces with the certified GTN750 GPS navigator. You'll also notice the round gauges in the center of the panel. Should the changes to Part 23 fall by the wayside, those traditional gauges could be used as primary, while the surrounding Vision Touch is technically used for backup.

Flight Design says the decision to use a system that does not have a TSO approval on its own, but will be certified together with the airframe, allows for a significantly lower price point. While the Part 23 revision is delayed until at least 2017, we'll be following it closely.
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Title Annotation:Dynon's SkyView Touch
Publication:The Aviation Consumer
Article Type:Product/service evaluation
Date:Oct 1, 2014
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