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Non-TSO’d avionics in certified airplanes: Have we taken the first step down a slippery slope?

While I’m usually really happy to see any avionics development getting industry headlines, one recent headline has me a lot more concerned than excited: Namely, it’s the announcement by the EAA that they have “partnered” with Dynon and the FAA to earn an STC to use a non-TSO’d Dynon PFD as the primary attitude indicator in “specific” Cessna and Piper aircraft.  


A Polarizing Announcement

To say it’s been a polarizing announcement is an understatement. I’d say it was tied with ADS-B as the number one topic of conversation during the recent AEA Convention in Orlando. For our part, I’ve talked to a number of dealers and they're pretty much split on it. Some see it as an opportunity to attract owners who are looking for the “low price solution.” Other, usually larger, more solutions oriented shops, see it more as a problem because customers will now buy solely on price and not so much selecting the avionics that may best fit their needs.

Let’s face it: price has always been an issue – but now I’m afraid it may well turn the tides on safety. There, I said it. As an manufacturer of FAA Part 23 TSO’d avionics, Genesys Aerosystems, and a host of other companies, spend thousands of hours and hundreds of thousands of dollars designing, testing and certifying our avionics to the highest possible performance, reliability, software and safety standards.

Most, if not all, manufacturers of non-TSO’d avionics don’t, nor do they have to, go to those lengths when introducing a new product. So you have to wonder why the EAA and FAA decided this was a good idea? And, if you aren’t wondering you should be – if the FAA’s concern for the safety of Part 23 aircraft is actually waning under pressure from select alphabet groups??


The Price Point

Which leads me back to the price point. Sure the non-TSO’d solution is cheaper, but will it be so in the long run? Can these units be repaired? Can the owners get the latest software updates when they come out? My understanding is, at least as far as the EAA/Dynon STC is concerned, the answer to both of these questions is no. The STC only covers the Dynon EFIS-D10A with a specific software version. Updates are not allowed. (Of course, that’s not to say that some owners and less than reputable avionics shops won’t try to do it.)

But now that the box is opened, will the FAA allow some kind of variance to the STC down the road? After all, six-months ago the idea of getting the FAA to allow non-TSO’d or PMA’d equipment in a certified airplane was unheard of. So what’s to stop the manufacturer of an “experimental” autopilot from getting an STC for their equipment in a 172 or Archer? How will these manufacturers supply the FAA with a suitable level of design assurance? Your guess is as good as mine. 

So you have to ask yourself, if the FAA was going to “partner” with an avionics manufacturer in the name of getting more advanced avionics into more aircraft at more “affordable” pricing, wouldn’t it have made more sense to work with the companies that already have all the approvals and certifications and find lower, less burdensome points of entry? I, and others, think so.

Anyway, the debate is just beginning. I don’t know what, if any, impact this recent approval is going to have the pending Part 23 rewrite, but I do know that I believe its set a bad precedence. And I am also concerned that customers who do not do their due diligence prior to buying a low-cost non-TSO’d product will end up wasting their money. Well, that’s my opinion anyway. What’s yours?



Until next time, fly safely,