FAA STC's for ADS-B Certification

What Has Become of our Industry Advocacy?

ROchs@spiritaeronautics.com (Rick Ochs) — Mon, 03 Apr 2023 12:32:21 GMT

What's In a Name?

At the 2022 AEA convention, as I sat joined by my peers in a large room full of people paying with their precious costs in time and money to attend, we were being warned by AEA that the use of the word Avionics was not universally understood so it must be removed from the Association's vernacular. Much effort was required to undertake such a feat, and the world will be a finer place following this program. Global unity on the much more well-understood term, aircraft electronics will undoubtedly ensue, as was explained during 30 minutes of this time.

Meanwhile, conversations on the convention floor centered around shop owners fretting about laying off employees because the main Avionics original equipment manufacturers could not deliver products for many months. Having no products meant having no source of revenue, and my fellow owners were right to be concerned for their company's future. No mention from the Association on these challenges and what to do to fix it.

While witnessing the audience's dismay at this lecture, I wondered how many companies sponsoring these folks to attend contain "Avionics" proudly in their business names. How many more are proud to explain to others what they do for a living using such a word as Avionics while grinning proudly? Yet these are the ones that must refrain from such a word as people in foreign lands may not understand. In my seat, I quickly found publications from EASA such as "Avionics requirements for Civil aircraft" or their Part 66- B2 Avionics License while being told EASA needs more clarity for conversations.

It was notable to read AEA's recap the following month in the Avionics News, April 2022; we're reminded in the article "What's In a Name?" to "stay tuned for updates on the membership language" about this need to remove such a maligned word such as Avionics.

The ADS-B rollout should have been a bright moment for AEA to shine. Its abysmal airworthiness certification path has been followed by its impaired performance. Aircraft were failing ADS-B Out performance requirements from its inception at over 30% for many years. It has only recently gone under 10% for "Non-Performing Emitters."

The FAA allowed ADS-B alterations to be undertaken by A&P mechanics, all the while AEA supported this path to subvert repair stations (Regular Members) that are typically required to maintain transponder systems. A UAT is designed to integrate and work properly with an existing transponder, yet no integration testing is required, allowing UAT's to be done outside of the Regular Member's companies by default.

I believe many of these UAT installations are responsible for the still too high ADS-B Non-Performing Emitter rate as the continued airworthiness certification path is broken, and the FAA struggles to fix it. The AEA should have done a much better job at helping the FAA to smartly roll out ADS-B. The Association should have been ardently protecting the ability of Regular Members to better participate and ensure ADS-B upgrades were only installed and serviced by qualified and properly equipped Repair stations. It did the opposite.

The current failure rate of ADS-B equipped aircraft is 5%, yet no one seems to care even as aircraft are now spaced together twice as tightly as before. The ADS-B airspace mandate is meant to provide a higher level of safety for half the separation as before; what is the level of risk with a 5% failure rate now inherent in the ATC system? If there was any other systemic failure of an airborne system, Airworthiness Directives (AD) would be flying out of FAA HQ to tell us why it's happening and what to do to fix it.

The FAA has been tripping all over itself on its 5G Cellular network Non-issue Airworthiness Directive, yet the AEA did not sign on to the 1st industry letter in opposition to the FAA's kneejerk reaction to someone saying Boo about 5G interference. It was quickly brushed over when the AEA had the FAA on the stage at the 2022 convention with a chance to dig into it to better understand how many interference events have happened. The AD couldn't acknowledge a single 5G interference incident in its AD from anywhere across the globe. The FAA is still very mum on the exact impact though any other AD would tell us why it's happening and what to do to fix it . The AEA needs to invest more effort in challenging this self-inflicted wound on the US aviation industry through independent study of the problem.

We are still waiting on the FAA & FCC to determine what to do about aircraft operating with 121.5MHz Emergency Locating Transmitters while NOAA no longer listens to them for distress beacon alerts. The FAA is still adamant that these same beacons are tested every 12 months (FAR 91.207), yet the absurdity is no one will hear them should they truly be needed to perform their lifesaving function. Where is the Avionics' industry advocacy to encourage the FAA to address this significant safety deficiency? For over 10 years, the AEA or FAA has yet to be in sight to address this fundamental safety issue of aircraft owners flying their FAA certified aircraft with safety systems that provide no benefit yet are to be routinely inspected.

The FAA now has a new Enterprise Resource Management system called SAS. This new acronym seems to be the latest four-letter word at the FAA to describe a bad cop that slows or stops every process in its tracks in the FAA bureaucracy. It has been wreaking havoc on the FAR 91, 135, and 121 operators in getting routine approvals for such things as Letter of Authorizations for RVSM approvals or aircraft registration changes completed in a timely manner.

The FAA has seemed to exempt Repair Stations from the pending SMS mandate despite the industry associations all championing its implementation. Associations such as the AEA are in a strained chorus with no melody to explain why it's needed other than everyone else seems to be doing it. Not a single person can tell the industry why another oversight program is necessary enough to be required to make us "Safer." They certainly are implying we are now unsafe, and SMS will quickly solve that problem.

Repair Stations are required to submit "Voluntary Disclosure Reports" to the FAA should a finding be made of a breach in the approved quality oversight of the company operations. SMS would duplicate this effort without the needed benefit of the reports being broadcast to the broader aviation community for review. What problem are they referring to that SMS will solve? The statistics for Repair stations induced errors resulting in injuries or fatalities are pitifully under-researched by the NTSB. What little data there is suggests that Repair Stations operate with exceptional safety results today. Can it be improved, of course. Can it be done by a new FAA policy the Administration couldn't implement upon itself when it tried 10 years ago? Let's discuss it with facts please, without puffy words or references to others doing it. The AEA should not be focused on leading FAA policy where ICAO goes as it diminishes the superpowers of the world's #1 avionics exporting nation.

The AEA has Associate Members that sell directly to aircraft owners such as Dynon. The AEA was founded to protect the Repair Station (Regular) members from FAA & industry-induced policies that run counter to the Member's benefits. I see this as one of the very worst violations of the AEA's pact with its foundational members in accepting money from such companies while subverting its Regular Member's best interests, as new product sales are critical to the lifeblood of these companies.

The AEA has a tremendous amount of dollars wrapped up in bonds and other fiduciary investment funds. The Association is expected to reuse excess funds to nurture and grow the opportunities for the Avionics industry. The funds that pay for more than the basic necessities of the association staff and routine business expenses must be reinvested in our community to better position it for current and future workforce challenges and regulatory change successes. Either the AEA revises its existing dues structure to only cover its needed expenses, or it uses these additional funds to benefit the members paying into it.

Maintaining a positive balance sheet for the Association is an expectation. Overcharging the members so the Association can hold positive investment capital is unwarranted and counter to the AEA's mission.

On a final note, the FAA's continued use of antique technology to operate the NOTAMS and METARS systems must be called and with actionable paths forward utilizing the incredible resources of the avionics industry.

The FAA continues to communicate vital information for flight crews based on a cost-per-letter protocol from the previous use of teletype machines to relay this data. As a result, student pilots must learn an entirely new language of acronyms only to read a NOTAM or METAR when they should be concentrating on far more essential things to be known as aviators. Current technology allows NOTAMS and METARS to be easily read without the added risk of misreading the bizarre string of letters & numbers that is currently in use. The AEA should be effectively leading the charge to empower the FAA with real messaging solutions that use plain language without pilots having to decipher any information whatsoever.

Getting new FAA approvals on Supplemental Type Certificates is far more time-consuming and frustrating than ever. Field Approvals for major alterations have become a thing of the past for many Regular Members in their FAA regions. Many FAA employees still work from home, directly contributing to very costly delays in certification programs and regular FAA duties as needed by AEA member companies. These are critical issues that the membership trusts for advocacy, yet there is little to no public discussions around them by the AEA.

Directly leveraging the subject matter experts within the AEA community to impact aviation safety is the heart of the Association. I believe the regular member companies should be more directly involved in many of the decisions and dialog more closely with the appropriate regulatory agencies with new ideas for process improvements and safety enhancements. These ideas are not getting through today.

The AEA's positions should be well-known and articulated regarding public input on aviation regulatory matters. The AEA only replicates instructions on the notices of proposed rulemaking or draft advisory documents instead of explaining the good or not-so-good elements of new regulatory policy and guidance for the membership. In these explanations, the Association is expected to pick the members' side and offer ideas and suggestions for improvement. The individual members can then amplify these suggestions to offer a more robust response to these calls for public comments on new regulatory policies and guidance directly impacting the Member's ability to operate safely, efficiently and profitably.

The name change coincides with the loss of identity that Avionics-centric Repair Stations feel due to the quiet elimination of FAR 145 Appendix A which gave clarity to the technical requirements and privileges unique to Radio class rated Repair Stations. Now that the FAA has made Appendix A disappear without objection from the AEA, most of the AEA's regular members operating under Radio Class ratings are fast becoming a relic of the past. Despite the fact this clearly is FAA policy backdoored onto the Radio Class Repair stations for no apparent reason, the AEA has seemed wholly content with this path with its silence & tacit support on the matter. This is bad policy in that it eliminates a well-standardized approach to best support the AEA membership in working with their FAA certificate holding district office to qualify their FAA certified operations specifications. Since this shift, every repair is now unique in its Operations Specifications using obscure Limited Airframe ratings. There is no standardization any longer where there once was a great system using Radio class ratings for Repair Stations. Even though it was overdue for an update, FAR 145 Appendix A provided clarity where all participants knew the baseline for a shop's technical requirements & privileges when it was well defined for Radio Class rated Repair Stations. Now there is no standardization and plenty of gray areas for avionics-centric repair stations to qualify their business with their FAA Inspectors, many of whom are AEA members.

The AEA now sides far more tightly with the FAA and its Associate members on many important issues to the industry at large. Repair Station's foundational needs are unchanged today from the Avionics industry's earliest days as needing strong advocacy to bring regulatory sanity and a level playing field for the Repair Station companies working hard to do honest business. It must recognize its core mission in supporting the Regular Member / Repair Stations and change to advocate for them more effectively or admit it no longer represents these values. Repair Stations as company members can value the expenses in time and money in their membership dues and participation activities by having more transparency and truly positive advocacy from the Aircraft Electronics Association.

1 http://www.brightcopy.net/allen/avne/59-4/index.php#/p/16

2 https://www.faa.gov/air_traffic/technology/equipadsb/installation/current_equipage_levels

from a different source.

Airframes That Outlive Their Avionics

ROchs@spiritaeronautics.com (Rick Ochs) — Thu, 19 Jan 2023 01:28:51 GMT

Keep The Aircraft, Transform Your Panel

Avionics, by design, are built with follow-on technical & parts support to allow for decades of service past their born-on date. This is a practice driven mainly by aircraft manufacturers demanding comprehensive product support services for their airline customers.

The consumer electronics industry operates in stark contrast to the Aviation model of product support. The discreet components used in most avionics are sourced from the same vendors as consumer-based electronics manufacturers. Due to consumer electronics market demands, life cycle support is very short-lived for these part makers, such as chip or display manufacturers.

The avionics sector is a small part of the broader electronics industry; we don't usually get the opportunity to hold these discreet parts manufacturers to the longer-term support needs of the aerospace industry. Despite this significant handicap, the avionic manufacturers support their products for decades beyond their initial build date. Unfortunately, Father Time and the winds of change will not relent in forcing the Avionic OEMs to sunset product support.

Aircraft have enjoyed strong growth in market appreciation in recent years. This effect allows many legacy aircraft to be considered for significant avionic investments, whereas the value equation was not there in previous years. The mission capabilities of legacy aircraft models meet today's new aircraft performance specifications. Resolving avionics obsolescence issues can reward owners with an aircraft that matches new aircraft speeds and ranges while remaining at levels of affordability necessary for the owner to keep flying safely.

Modernized aircraft considered by the FAA as "Best Equipped" will be "Best Served," avoiding delays while maintaining the business tool's time machine effect payback . These technology updates can offer owners equal airspace access for best equipped/best served using DataComm avionics, enabling messaging between aircrews and Air Traffic Controllers and reducing or eliminating airspace holds/delays.

KEEP THE AIRCRAFT. UPGRADES THAT SAVE

Enhanced airspace navigation and landing capabilities, such as RNP & LPV can be accomplished with an avionics upgrade more cost-effectively than purchasing a new airplane to gain these operational benefits. Want to stay connected when you're in the air? No one is asking for less data throughput to keep passengers productive while enroute to their destination. Legacy cabin WIFI systems are considered obsolete if not upgraded within the previous three to five years.

At the scale of cost for a new aircraft, the business of avionics retrofits has been a growing enterprise tracking the always-accelerating air travel needs of people everywhere.

Using the venerable Cessna 182 as an example, the model first flew in the late 1950s. The airframe itself has remained relatively unchanged since it began full-scale production. The Skylane is still built today with refinements in the airframe and powerplant, yet the revolutionary changes are in the cockpit. These same revolutionary changes can be applied to the legacy model Skylanes allowing them to offer safety, reliability, and advanced features as a new Skylane cockpit. Older aircraft carry the same loads at similar speeds and ranges as new aircraft. Why spend more money than you have to? Legacy Skylane's have a solid airframe, powerplant, and propeller. The same can be said for the Boeing 737, born in 1969 yet still produced new today.

New product innovations for obsolete avionics can sometimes emanate from the retrofit industry and then carry into the forward fit design for new aircraft. Cabin entertainment systems in business aircraft can rival the best home theater systems for passengers. Revolutionary new audio technologies, such as those from Bongiovie Acoustics' speakerless audio systems, can bring a complete immersion in watching a movie on new HD monitors in aircraft cabins. Simply addressing cabin entertainment systems for obsolescence will lead to a much better passenger media experience. Sometimes it can truly impress the most discerning audiophile.

New avionic displays are manufactured specifically to become a direct replacement for legacy CRT-type cockpit displays. These new displays offer a "Drop-in Replacement" solution for obsolete green screen displays using "TV Tube" technology. Gaining FAA approvals for a significant update to Primary Flight Displays is a very complex process that is expensive in time and money. Offering drop-in display replacements is a cost-effective way to address obsolescence in viable aircraft. As a real benefit, it increases safety by enhancing flight crew situational awareness as a very significant enhancement. The plane becomes more valuable by increasing the dispatch reliability and operational capabilities. Reestablishing all necessary follow-on technical and parts support needs of complex systems no longer deemed airworthy is essential for all aircraft. Most times, it also adds safety to the value equation.

Airframe and powerplants changes are refinements over time. Avionics changes come in revolutionary ways.

Spirit Aeronautics Thrives On Happy Customers

Wed, 30 Nov 2022 13:49:35 GMT

Personalized Service & Solutions Tailored To Your Needs

The way Rick Ochs sees it, there are lots of advantages to being a relatively small avionics company serving business aircraft owners and operators. For starters, there’s the ability of his company— Spirit Aeronautics —to provide customers with personalized services and solutions tailored to their needs. “Every customer is unique,” said Ochs, Spirit’s President and CEO. “As a small, close-knit team of about 30 people, we take the time to learn about our customers and advise them on the best options for their particular aircraft, mission and operating style. We’re not happy until the customer is happy.”

With operations in Columbus, Ohio, and Ft. Worth, Texas, Spirit Aeronautics prides itself on going above and beyond for customers, which include NASA, the military, other government agencies and corporate flight departments. “If I had to choose a word to describe us, it would be ‘responsive,’” Ochs said. “Our customers know that we’re always there for them and they have a direct line to anyone in the company, including me.” That kind of dedication—backed by superior performance—explains why Spirit Aeronautics has been a Honeywell Aerospace preferred channel partner for more than two decades.

“Honeywell Has Been A Tremendous Partner For Us And We’ve Had Enormous Success Over The Years Working Together On All Kinds Of Programs,” Ochs Said. “After 20-Plus Years, We Know How Honeywell Works And We Know The Right People To Call To Expedite Solutions For Our Customers.”

For example, Spirit Aeronautics is a major handler of Honeywell rotables, providing factory spares and replacement parts to all kinds of operators. The company is also a leading advocate for the Honeywell Maintenance Service Plan (MSP) – Avionics , business aviation’s premier aftermarket services solution. “MSP-Avionics is great solution for our customers, because it helps them control maintenance, repair and overhaul spending and avoid costly aircraft on the ground situations,” Ochs said. The Spirit Aeronautics team is currently helping customers upgrade to Honeywell’s most advanced weather radar, the IntuVue RDR-7000 , which was developed to meet the needs of business aviation.

“The RDR-7000 Is The Logical Replacement For The Honeywell Primus 880, 660 And 440 Radars,” Ochs Said. “Honeywell Has Discontinued Production And Will End Its Support Of These Obsolete Systems In 2024. We’re Advising Our Customers Not To Wait Until The Last Minute And To Take Advantage Of The Deep Discounts Before The End Of The Year. They Should Plan And Budget For The Upgrade Now So They Won’t Be Caught Short If Something Happens To Their Primus Radar.”

The RDR-7000 outperforms legacy weather radars, literally by miles. Conventional weather radars scan only a portion of the sky. But the RDR-7000 scans the entire volume of air in front of the aircraft from the ground to 60,000 feet and up to 320 nautical miles along and adjacent to the flight path. Honeywell engineers developed a technique called 3-D volumetric scanning to analyze storm clouds and search for conditions that might produce lightning, hail, turbulence or wind shear. Then it displays those conditions with easy-to-understand symbology—like small lightning bolts—so pilots can clearly see what kinds of conditions they’re facing.

Honeywell is currently offering incentives, discounts and trade-in allowances on the RDR-7000 radar. These include a $65,000 trade-in credit, as well as an MSP-Avionics discount of $30,000 for operators signing a new three-year contract. Additional incentives are available to operators upgrading multiple aircraft to the RDR-7000.

“The RDR-7000 Is Hands-Down The World’s Best Radar,” Ochs Said. “Plus, It’s A Drop-In Replacement For Our Customers’ Current Primus Systems. Right Now, We Can Perform The Upgrade In Less Than A Week.”

Revolutionary Changes in Avionics-Transforming Legacy Aircraft

Mon, 16 May 2022 14:58:40 GMT

Parts Obsolescence

Parts obsolescence is a significant challenge for anything built that remains in operation long after the product's manufacture & support has expired. Aircraft system life cycles are much longer than technology life cycles in the aerospace industry. Airframe designs survive many decades relatively unchanged, while onboard electronics become obsolete much faster.

The continued avionics modifications and upgrades in the aerospace industry have far exceeded any consumer-grade electronic systems for ongoing support in many cases for avionics equipment and software. The time is upon us now to modernize systems and keep these expensive assets serviceable and marketable for many aircraft.

Examples such as the Boeing 737 & 747 are aircraft that have remained fundamentally the same since their inception 50 years ago. Other than an increase in size, their significant changes have involved engines and avionics over these many decades. The engines gained high bypass turbofans as an excellent refinement while the avionics have changed in revolutionary ways, much as the consumer electronics industry has performed since 1969.

This cycle for avionics equipment development and the long service life is in stark comparison to other markets such as consumer and commercial electronics. The electronics parts manufacturing industry responds quickly to consumer electronics while the avionics’ manufacturing industry is slow to produce with extensive certification requirements and testing. The manufacturers of the small, discreet electronics components quickly march on with new product development and support. Leaving long-standing avionics products with limited parts support for the many ongoing years where the manufacturers are still required to sustain current generation avionics

Electronic repair shops have all but disappeared for radio and TV repairs within the past few decades. Consumer electronics become disposable once they reach the end of a concise life. The technology often moves on, and the device quickly becomes obsolete due to consumer demand for newer tech and/or lack of support for electronic device repairs. Many avionics systems in legacy aircraft are still supported and operating after 30 years or more. It's a remarkable achievement for the aviation industry; anything built for the consumer electronics industry can rarely match these results.

The efforts to keep these systems viable go by many different titles and acronyms. The US Department of Defense refers to the lack of ongoing support for legacy equipment as Diminishing Manufacturing Sources and Material Shortages (DMSMS). DMSMS issues are inevitable for the military as acquisition processes are very long and new product development is expensive relative to maintaining the support of legacy systems in current and critical use phases. DMSMS issues affect material readiness and operational availability, which, in turn, affect both combat operations and personnel safety.

Parts obsolescence is becoming more pronounced in the current business aircraft market environment as older aircraft have regained a significant increase in their market values.

Airframes considered near or end of life are fast becoming candidates for significant modernization efforts.

Revolutionary changes in electronics have transformed legacy aircraft and brought them into the 21st century, allowing many well-supported legacy aircraft models to operate like new for the owner. Saving money in total aircraft costs while enhancing the safety, utility, and viability of many excellent legacy aircraft is supported by a strong aftermarket MRO industry, including companies like Spirit Aeronautics, specializing in aircraft systems modernizations.

What is Flight Operations Quality Assurance & Why is it Important?

Thu, 21 Jan 2021 22:26:05 GMT

How FOQA Can Help Pilots & The Aviation Community

Flight Operations Quality Assurance (FOQA) is a safety program designed to make aviation safer by allowing aircraft operators, pilots, maintenance crews and engineers to share and analyze de-identified aggregated information as downloaded from the existing Digital Flight Data Recorder (FDR) installed on many aircraft. FOQA analysis provides deep access to rich flight data of aircraft operational and health information and presenting it in an easy-to-understand format. This well-organized information allows users to identify flights and procedures that require further review. Aircraft operators get instant access to past and current flight data enabling detailed reports while identifying trends.
Known as flight parameters, aircraft performance information that is normally recorded on a Digital Flight Data Recorder is utilized by a FOQA program in an active manner to identify trends in flight operations while also providing health monitoring of aircraft systems, powerplants and aerodynamic performance. Thousands of flight parameter data points are downloaded via a data retrieval device known as a Quick Access Recorder (QAR) or from the FDR itself.

The QAR, with storage capacity much greater than any FDR, automatically records many parameters of data from the past flight and makes for easy transmission to FOQA services providers for decoding, analysis and reporting services. Many FOQA reports utilize innovative graphic visualizations of flight activity for easy interpretation of the vast amounts of data now available to be reviewed. This data is immediately reviewed against the historical records of like-type aircraft and/or flight operations for direct comparisons of aircraft performance. Software tools apply algorithms to identify suspect flight parameter patterns and highlight them allowing the aircraft operator to review them in greater detail. The results are stored indefinitely, adding to the trove of valuable historical data used for aircraft operational analysis for associated FOQA programs throughout the world.

FOQA is important for many good reasons including increased safety, maintenance planning and pilot training during simulated, instructor-led or real-world flight events. FOQA is a safety tool providing highly detailed, graphic rich, prompt feedback to the global flight community. This capability contributes immediate operational improvements as it increases air safety for pilots and aircraft alike across all operational spectrums.

Air safety is improved with the identification of risks and hazards due to abnormal OR normal operating procedures. Standard Procedures may include latent vulnerabilities as determined by well analyzed observations of aircraft operating methods and practices while flying them. Flight crew performance benefit greatly with more constructive feedback and precise training regimes for each pilot. Operational matters such as air carrier training programs, airline operating procedures, air traffic control procedures, airport maintenance & design and aircraft maintenance & design can also benefit.

The highest value of FOQA programs is the early identification of adverse safety trends that, if uncorrected, could lead to accidents. A key element in FOQA is of its ability to suggest corrective action needed to assure that unsafe or inefficient conditions are effectively resolved.

A flight department with one aircraft, on-demand charter operators on up to commercial airlines with large fleets of aircraft can all operate their FOQA programs independently or they can participate in a deidentified data sharing platform such as the International Air Transportation Association’s Flight Data eXchange (FDX) or the FAA’s Aviation Safety Information Analysis and Sharing (ASIAS) platform. IATA’s FDX and the FAA’s ASIAS platform help to monitor global trends or national trends respectively in aircraft operations. Operational risk issues such as flight operations, air traffic control, airports & aircraft designs are benchmarked against 8 million other flights for identifying safety risks.

The fundamental objective of the FAA / pilot / air carrier partnership is to allow all three parties to identify and reduce or eliminate safety risks along with minimizing deviations from the regulations. To achieve this objective and obtain valuable safety information, the airlines, pilots and the FAA are voluntarily agreeing to participate in this program so that all three organizations can achieve a mutual goal of making air travel safer. A cornerstone of this program is the understanding that aggregate data that is provided to the FAA will be kept confidential and the identity of reporting pilots or airlines will remain anonymous as allowed by law.

In recent years, the FAA and the air transportation industry have sought additional means for addressing safety problems and identifying potential safety hazards. Based on the experiences of foreign air carriers, the results of several FAA-sponsored studies and input received from government/industry safety forums, the FAA has concluded that wide implementation of FOQA programs could have significant potential to reduce air carrier accident rates below current levels.

As a result of an ICAO recommendation, all airlines and operations that meet certain criteria are required under regional legislation to implement Flight Data Monitoring programs. However, in the United States, the Federal Aviation Administration does not yet require FOQA programs for commercial aircraft operators. The current European Aviation Safety Agency requirements mandate European registered aircraft weighing 27,000 kg or more, to be included in a structured flight data analysis program.

The FAA defined FOQA in its Advisory Circular #120-82, originally released April 12, 2004. The agency's Air Transportation Operations Inspector's Handbook - FAA Order 8400.10 details what a valid FOQA system contains. An excerpt from this document summarizes FOQA as a “voluntary safety program designed to improve aviation safety through the proactive use of flight-recorded data.”

Though voluntary, nearly every major airline in the United States maintains a robust flight data analysis program. Charter operators, Flight schools and privately managed flight departments with multiple aircraft are rapidly adopting voluntary FOQA as a standard practice because of the value of the information. FOQA unlocks critical performance and operational indicators in fuel management and flight efficiency, maintenance, procedural safety, block time analysis and ground turn optimization. This timely and accurate data enables airlines and fleet operators to rapidly make improvements to operational inefficiencies. Hidden inefficiencies are identified enabling a better customer experience and increased profitability for the aircraft operators. Flight schools and Simulator Training Providers can utilize this data for a more targeting training syllabus for each student while strictly monitoring the operational stresses imparted on fleets of training aircraft.

Airframe, avionics and engine trend information is reviewed to determine the nature of any required preventative or needed maintenance actions. Such actions might include the immediate notification of maintenance personnel if limits were exceeded that require inspection of the aircraft, reviews of a failure event to identify possible corrective measures or a determination that further actions are needed. Savings in costs of time and money are a powerful reason to utilize a FOQA program to maintain the best health of the aircraft while extracting the full value of its mission capabilities.

The benefits of implementing a FOQA program:

• Identify significant unsafe events allowing the operator to take appropriate action

• Perform trend analysis to highlight safety issues

• Benchmark your operations against a global database

• Focus training in specific areas (enhanced evidence-based training)

• Minimize unscheduled Aircraft on Ground (AOG) time

• Empower maintenance department to have access to data within minutes of landing

• Enable rapid diagnosis of issues and faster release of aircraft

Advantages to a Corporate Flight Dept. FOQA program besides statistical analysis, include

• Optimize practices and processes to minimize safety events by identifying areas of improvement in Standard Operational Procedures.

• Monitoring aircraft performance.

• Improving training programs by tailoring your policies and training programs to reduce safety events.

• Monitoring maintenance events and troubleshooting aircraft maintenance issues.

• Detecting airport operational issues related to:

• Arrival/departure procedure issues

• Late ATC Clearances

• Traffic Collision Avoidance System Alerts

Key features of a FOQA program:

Statistical Analysis. This is used to create profiles of flight, maintenance, or engineering operational procedures. The profiles can use several measurements to facilitate distributions of various criteria. A distribution of data will show all flights and enable an aircraft operator to draw comparisons with benchmarked data drawn from the global flight community.

Exceedance Analysis. This involves setting a specific limit for the flight data analysis program to detect for a particular parameter or set of parameters. As examples, the algorithms can be programmed to detect each time the aircraft roll angle exceeds 45 degrees or in the case of multi-state parameters, when an approach becomes unstable. This data can be evaluated over multiple flights to determine the number of exceedances occurring per flight segments to identify trends in aircraft operations.

Key ways in which FDM/FOQA can save an operator costs:

You may prevent a devastating accident or costly incident.
You may save money in engine trend costs, and possibly extend the life of the engine.
You may save money in aircraft maintenance costs by finding and eliminating non-SOP flight techniques.
You may save insurance costs. Many insurance companies will reduce rates if an operator can quantify their safety levels and demonstrate they are managing safety.
You may save fuel costs. An intelligent fuel monitoring program will identify practices in flight operations where fuel usage can be reduced.
Flight planning can be more finely tuned to the aircraft for expected weather conditions and route planning decision making responsibilities.

For more information, please call Rick Ochs at 614.537.3052 to download this full blog click here

The impact of using an FAA STC for ADS-B Pairing approvals

Wed, 29 Jul 2020 12:28:16 GMT

ADS-B Beyond 2020

The problem has always been, this pairing specification is highly defined and is now locked in state due to product part numbers tied to the STC by the FAA thru its approval of the ADS-B installation via an STC.

The current failure rates of installed system validates that ADS-B installations are being accomplished without proper test equipment and specially trained technicians involved.

- Rick Ochs, CEO

Through a myriad of requirements driven by an Advisory Circular, the Federal Aviation Administration (FAA) deemed that all ADS-B installations can only be qualified using an FAA approved Type Certificate, an Amended Type Certificate or a Supplemental Type Certificate (STC) process. This process is used to validate the equipment pairing of an ADS-B compliant Transponder & WAAS GPS sensor to make up an approved ADS-B solution. This STC may then be applied to any number of aircraft that can utilize the component pairing defined in the STC to qualify as a new, FAA approved ADS-B compliance solution for the aircraft owner.

Currently, the failure rate of ADS-B equipped aircraft is over 9% as averaged over all aircraft in US domestic service for the first 6 months of 2020. This measure is drawn directly from the FAA website for current US equipage levels of ADS-B compliant aircraft. This exceptionally high average failure rate is derived from the difference between “Good Installs” and “Non-Performing Emitters”. According to the FAA, these failures are almost exclusively a result of ADS-B system misconfigurations deemed as “Installation Errors” and not Transponder or WAAS GPS equipment failures. Rarely, if ever is the ADS-B failure alerted to the pilot via the newly install ADS-F Fail annunciator that drives the need for a new Airplane Flight Manual Supplement.

An ADS-B STC project Safety Analysis requires a reliability factor of 10 to the negative 9th power to gain FAA approval. Systematically, ADS-B as deployed is operating at 10 to the negative 1st power. If this were any other systematic failure with such highly defined causes, the Airworthiness Directives would be flying out of D.C. to address and resolve it. This problem is rarely acknowledged for the scale of it and nothing has been discussed or offered to get it quickly resolved by the FAA. We need to know why it is happening and what more needs to be done to resolve it.

I believe that a major cause of ADS-B system misconfigurations are driven by the STC. Avionics installers working on an ADS-B project that have an STC data package in front of them, may be mostly referring to it though it was developed for an entirely different aircraft. The configuration settings may be wholly different than what is required for the new installation. If there may be questions on a setting, the installer may be using what is believed to be an FAA approval to set ADS-B parameters that are likely erroneous to configure the new installation.

Installers must have the proper training and test equipment and internal processes to validate and record the proper operation and configuration settings to authorize the ADS-B system operations. ADS-B installations by their nature integrate with the very systems as identified in FAR 91.413 and FAR 43 Appendix F. With that, ADS-B installations MUST only be accomplished and the aircraft approved for Return to Service by an appropriately rated FAA certified Repair Station.

Any installation approved by an Inspection Authorized Airframe & Powerplant Mechanic (IA) cannot be deemed legal and should always be highly discouraged. Suggesting an IA do an ADS-B installation and then the aircraft should go to a Repair Station for final airworthiness signoff is unwise, uncommon and useless as a suggested path for an aircraft owner.

Many challenges exist with the current ADS-B airworthiness certification path. This “Pairing” must be approved via STC with very few other alternatives for ADS-B system installation approval. There has never been such a certification scheme by the FAA to Supplement something that was never Type Certified to begin with (as far as I can tell). This fact presents unforeseen challenges.

Normally, an STC is applicable to a Type Certification of an actual aircraft. In the case of ADS-B, a pairing is used as a basis for an STC project though a real aircraft is identified as the engineering baseline in the certification plan to administer the STC. All engineering and testing now involved with the installation becomes a part of the STC. Much or very little of the STC can then be applied to any number of aircraft that can use that same Transponder/WAAS GPS electrical pairing to gain ADS-B compliance.

The problem has always been, this pairing technical specification is highly defined and is now locked in state due by the FAA thru its approval of the ADS-B installation via an STC. There can be no software or hardware changes to either device throughout the life of the applicable pairing STC without subsequent engineering reviews, TESTING and FAA approvals of amended STC’s.

It is inevitable that through s short span of time, the STC will need to be amended or replaced with an entirely new STC. This is due to the reality of software or hardware changes that occur with a modification to either paired device that happen as OEM manufacturing processes mandate. These firmware changes are a normal function of product improvement in a manufacturing environment. These modifications may or may not involve a unit part number change.

Such as the case with a WAAS GPS sensor that has recently been deemed to have a software bug that was not discovered when it was built and certified for approved WAAS GPS LPV approach operations along with ADS-B capabilities. The same GPS is used for both navigation and ADS-B position reporting. This software bug can only be resolved with a major software change and a part number roll to a new part number of the same model number WAAS GPS. Though not required for ADS-B continued airworthiness, that change will now affect every single jet in operation that has already been upgraded to these WAAS GPS units for ADS-B compliance. Should it require service, it will come back with a different part number from an OEM repair.

The worst time to find out about a different part number provided to replace a failed unit is when the time comes for a proper logbook entry to sign off what should be a routine ADS-B maintenance event. No alternative part numbers or software changes have been approved under the ADS-B STC used for compliance that is now in jeopardy as the failed part number unit is no longer readily available. Any new or exchange/overhauled unit from the OEM will come with the new firmware change due to manufacturing quality assurance processes. A quick turn maintenance event to get a working aircraft back in service is not to find out that a new STC is now required due to parts obsolescence driven by product improvement processes.

Anytime a GPS or transponder is sent into the OEM for any repairs, it may come back with a different software level or hardware part number. This action will deem it to be unacceptable for reinstallation in the aircraft that it was removed from. This is because the repaired unit, with a different software or part number will no longer comply with the STC that it was originally certified to for the aircraft undergoing ADS-B maintenance. There can be no deviations for future enhancements to the approved pairing that makes up the ADS-B source equipment without the STC being amended or replaced with a new STC.

If we are going to be honest about it, in such a simple STC that exists primarily for the digital databus pairing of 2 discrete components which may be different product OEM’s, any and all software or firmware change is a major change to the STC. That means a new STC is in order as an amendment is not recognized for an STC application to make any product improvement changes.

Additionally, if the ADS-B component manufacturer is not the owner of the STC as utilized for the ADS-B installation, the “3rd party STC Holder” may not / will not amend or replace their previous STC to maintain current airworthiness standards of any aircraft affected. An aircraft that is AOG for ADS-B will suffer significantly in need of a new airworthiness path for what should be a normal maintenance event. This is a major problem now for many in the avionics and MRO community that service ADS-B systems.

My idea for a solution is also a great attribute for repair stations that spend so much time, heart and intellect supporting the continuous FAA oversight and approval of aircraft Return to Service processes. An ADS-B installation should be considered a Major aircraft alteration yet not a major change to the Type Design for any aircraft. (If the same WAAS GPS is used as a navigation source, this is an entirely different topic relative that that system’s ongoing airworthiness approvals.)

The FAA should grant privileges to Repair Stations to install and recertify ADS-B system installations per under new Operations Specifications. Return to Service approvals for ADS-B systems using normal requirements of proper tooling, training, personnel and facilities and a Quality Controlled process as required under FAR 145 should be perfectly leveraged to provide this needed service. This is a simple plan and it will effectively address the current extraordinary in-service failure rates of deployed ADS-B systems.

The FAA should certainly enable Repair Stations actual privileges for ADS-B installations with full system integration validations and Return to Service airworthiness certifications. The current failure rates of installed systems validates that ADS-B installations should not be accomplished without proper test equipment and specially trained avionics technicians involved. FAR regulations have made clear for decades that any Transponder or altitude encoding system maintenance must be done by an appropriately rated & certified Repair Station. All 1090 ADS-B Out upgrades involve these systems along with the majority of 973MHz UAT systems.

Through 14 CFR, FAR 145 approved Repair Station Operations Specifications, ADS-B system integration, installation and testing along with an affirmative Public ADS-B Performance Report from the FAA ADS-B website should form the basis of the proper continued airworthiness needs of ADS-B system integration. This is no different than Transponder and Altimetry systems are maintained today.

As an example of previous FAA airworthiness approval processing, GPS navigation receivers in aircraft used to require an STC for IFR approach capability approvals when they were considered new and novel. The FAA provided installation approval policy to enable a VFR only installation until such time a test flight was flown consisting of 3 successful GPS approaches and a defined error parameter worksheet was completed that was made a part of any applicable GPS IFR work order. Once the test flight was completed, another FAA Form 337 was completed, an Airplane Flight Manual Supplement was incorporated into the aircraft documents, and the aircraft was approved for IFR operations as noted by a new placard stuck to the instrument panel.

This plan will better leverage Repair Stations to eliminate the excessive failures rates of all ADS-B equipped aircraft in the ATC system today. It is a common-sense approach to ADS-B system reliability and the ever-evolving ongoing maintenance requirements for NextGen operations.