Gripdana wrote:I was able to get them by email. This is a bummer since I received my EXP just prior to the notice. I thought an AD could/would not cover any equipment or aircraft that is experimental. That said it is also my understanding that the ADS-B equipment for experimental only needs to meet and perform to the standards of the ruling. So if the internal GPS in question performs to the standards, the EXP should be excluded from the proposed AD.
Your experimental status will not get you out of this one.
As you pointed out, when interfacing with ATC (navigation systems, transponders, etc.), an experimental aircraft still has to meet the appropriate performance requirements. For something like a GPS source, it is typically infeasible for the buyer to test and confirm (especially the integrity and reliability requirements), so you will naturally defer to the manufacturer for that confirmation (be it by TSO or some other standard).
My understanding of this situation (read the
emergency order) is that Navworx modified the firmware of their device to report a non-zero Source Integrity Level (SIL) in the ADS-B packet. The FAA claims that Navworx has not provided it with the necessary information to confirm that their hardware actually meets the performance it is reporting. At this point, if you want to fall back on your experimental status to get you out of this, you would then have to go through the process of demonstrating your hardware meets the claimed integrity requirements.
An integrity score of zero (no integrity guarantees) is perfectly legal up until the 2020 mandate, at which a specific integrity level is required (read
14 CFR 91.225 and
227 if you really want the details). If your Navworx is reporting an integrity of zero, you "should" be fine up until midnight on 2019-12-31. If your unit is reporting anything else, you'll have a problem.
From my perspective, it seems like the easiest solution for Navworx would be release a firmware update that simply reverts the SIL to zero. That would resolve the immediate airworthiness issue. They could then work with the FAA to get the SIL upgraded prior to the 2020 mandate deadline.
Edit/Add: According to the
Navworx statement, they increased the SIL in response to an FAA decision where they were to terminate TIS-B services to aircraft squawking with a SIL of 0.