Going Direct: FAA Okays Retrofit Of Non-Certified Avionics In Certified Airplanes

The FAA on Wednesday took the historic step in advancing the cause of safety in light GA and in adding immeasurably to the value of the used fleet by okaying an avionics solution that’s unlike any in the history of the agency.

The news? On Wednesday, the EAA, which spearheaded the campaign, announced that the FAA has granted STC approval for the installation of the non-certificated Dynon EFIS-D10A primary attitude indicator to replace the antique, failure-prone and obsolete mechanical attitude instruments in the panels of Cessna 150, 152 and 172 and Piper PA-28 and PA-38 models. While that list is relatively short, it contains some of the most produced aircraft in GA history and represents many tens of thousands of airplanes in the fleet.

Going Direct: FAA Okays Retrofit Of Non-Certified Avionics In Certified Airplanes
Dynon EFIS-D10A primary attitude indicator

Dynon hasn’t released pricing of the instrument, but we expect it to be in line with the price of the experimental product. Dynon says it plans to reveal more details soon.

This isn’t the first time that the FAA has made such a move. Almost two years ago, it announced that it would allow the installation of non-certified angle of attack indicators in certified airplanes.

While, in theory, it’s an amazing idea, I’m skeptical about any widespread safety benefit of AOA instruments in GA birds flown by pilots with little or no professional training, the move signaled a change in the way the FAA viewed certification and risk. Instead of looking at the certification process, like it always had before, as a series of elaborate data-intensive hoops to jump through, the agency is now increasingly looking at it as a calculus driven by a single, magic question. Does the installation of the new instrument improve safety, degrade it or leave it unchanged?

In the case of the Dynon instrument, it without a shadow of a doubt improves safety tremendously. The lack of certification isn’t a net loss at all. In the case of an instrument that’s solid state with a digital display, it’s hard to imagine a hardware technology leap anymore profound than the spinning metal-teethed gyros of a dusty, old mechanical unit. Just because the new products haven’t gone through the million-dollar FAA wringer doesn’t mean they’re less safe than what they’re replacing, only that the FAA is less certain about their safety than they possibly could be. The net effect, and this is what really matters, is that these new instruments are 1,000 times safer than the mechanical ones they replace instead of 1,001 times safer (figures that are, of course, for the purpose of argument).

I don’t know about you, but we’ll give up that potential one-tenth of a percentage point for the million dollar savings any day of the week.

So congrats to Dynon, the FAA, and to EAA for its work on the project. May it be the first of many more such approvals to come.

Visit Dynon at dynonavionics.com.

 

 

3 thoughts on “Going Direct: FAA Okays Retrofit Of Non-Certified Avionics In Certified Airplanes

  1. Be very careful guys. I’m a big fan of Dynon (having multiple Skyview screens in my IFR Rocket), but just because an electronic system works now does not mean that a screen backlight failure or seemingly minor software update cannot render the displays entire functionality unusable in a heartbeat. For this reason multiple redundant systems based on a different hardware/software configuration basis are important for IFR safety (exactly why Garmin has developed the new G5 to complement their own highly reliable primary systems). Note that multiple screens in say a G1000 system (PFD/MFD), for example, are not tantamount to system redundancy. The backup steam gauges exist alongside the G1000 in a Cessna or Cirrus because there are critical background elements of the system architecutre (ADAHRS/ADC/magnetometer) that are NOT redundant.

  2. I’m not sure everyone looks at this issue from the FAA perspective or even why the FAA has all those whiz-bang, jump through the hoops requirements. Now don’t get me wrong, I applaud this decision and in this particular case I believe it to be the right one. However, non-certified is synonymous with “not tested”. No one knows what these things will do, when or how long or how well you can depend on them. In years past, people bought cheap junk at carnivals and such, it worked great for an hour or two, but by the time you got home it was broken and never worked again. You’d look on the inside and it said “Made in Japan” and so it became a stereotype, saying “Made in Japan” meant you bought a cheap piece of junk (this is seldom true of Japan anymore, but is still true of a great many countries if you’re not careful. Why? Because they make illegal copies of things that are good and work well, but because they do not understand the mechanism they don’t know how to avoid the pitfalls the designers and original manufacturers found and their products fail miserably. Testing would have solved that. Similarly, those companies now invent “original” items, but don’t know how to test, and those things fail as well. The facts are, and history has and continues to prove out that fact that testing improves quality, reliability and safety. The FAA knows that and it is why they have demanded so much in the way of testing. However, they have gone many, many miles overboard trying (and failing) to test every possible failure scenario to assure anything put in an airplane is failure proof. However there is no such thing. The FAA also knows that aerospace is a dangerous and hazardous environment because there are so few static conditions on which you can rely. Changes in altitude, temperature, humidity are dramatic over a flight envelope versus what you may encounter on the ground or water in a vehicle. Furthermore, aircraft are all handmade and dramatically different in approaches and an item that works perfectly in one aircraft, may be a complete failure in another. Something that works well at 28 volts may not work well on 12 volts. Something that works well at normal barometric pressures may not work well at 18,000 ft. I can go on and on, but that’s why there is so much testing, so you can count on it. One writer asked, why is this not done for Mooney’s and Beechcraft? My answer would be likely that Mooney’s and Beechcraft are frequently operated at speeds above 150 knots, at altitudes above 10,000 feet and land faster than 45-50 knots. The Cessna family and Piper family chosen fly low, fly slow and land slow and that keeps the environment tremendously more predictable and the operation shock and environment much more controllable and predictable, so they possess a modicum of confidence that there are few unforeseen events that will occur to these craft. Furthermore, they picked these craft because they are very similar to the currently installed base of Dynon products. Dynon is typically installed in amateur-built experimental aircraft. While there is no formal FAA testing, there are millions of hours of these products having successfully flown in the homebuilts and FAA/NTSB investigation of accidents of those craft seldom blame any Dynon product. Thus, there is extensive history in every conceivable environment with these products and while it is not perfect or empirically conducted using a Sir Francis Bacon approach, the confidence level is extremely high that these products are extremely safe in this particular family of airframe, powerplant and usage types. As the author said, they are not 100% sure, but 98-99% sure is pretty close and risk levels are at or above any reasonable level they would receive from FAA testing.

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