SkyGuard portable ADS-B out

[RotorDude]

I notice that SkyGuard is telling their customers that all their newer (post Aug. 1, 2015) portable ADS-B out units have been blessed by the FAA as clients, i.e. should elicit TIS-B replies from the ground stations. Their older units may be upgraded to the same standards by splitting the $100 cost of a factory GPS upgrade.
I was wondering if anyone here is aware of this development, since I recall some people saying that a portable ADS-B out will never be allowed by the FAA, and the existing loophole, where SIL=0 units are still allowed, will be closed by 2016.

 

[Scrabo]

Is have a bridge I can sell you......

I think Don is living in an alternative universe from the rest of us and the FAA.

While I like the idea of Skyguard and at one point purchased one, only to return it 2 days later, I strongly believe that the FAA will not allow ANY portable OUT units.

Same goes for the PADS unit.

We are still several years out from the mandate, lots of time for the FAA to flip flop and Don and others to try and sell units.

 

[Jim Logajan]

I notice that SkyGuard is telling their customers that all their newer (post Aug. 1, 2015) portable ADS-B out units have been blessed by the FAA as clients, i.e. should elicit TIS-B replies from the ground stations. Their older units may be upgraded to the same standards by splitting the $100 cost of a factory GPS upgrade.
I was wondering if anyone here is aware of this development, since I recall some people saying that a portable ADS-B out will never be allowed by the FAA, and the existing loophole, where SIL=0 units are still allowed, will be closed by 2016.

The FAA has not ruled portable units out, just limited their scope of use:

http://www.faa.gov/nextgen/programs/adsb/faq/#26

"Installed transponders and GPS units must meet certification standards. Handheld devices and displays that serve only for situational awareness have more flexibility and are not certified installations. In order to comply with 14 CFR § 91.225 and 91.227 aircraft intended to fly in ADS-B airspace must have installed and certified equipment. Portable installations are not compliant to the rule and would only be usable for receiving FIS-B services for situational awareness. The FAA is in the early stages of investigating a portable device for glider aircraft."

Also, 14 CFR § 91.225 begins with "(a) After January 1, 2020, ...." so anyone, including the FAA, claiming this or that is allowed or disallowed prior to that time per regulations is talking baloney. Only the FCC regulations currently have any relevance or legal legs.

 

[Scrabo]

....Portable installations are not compliant to the rule and would only be usable for receiving FIS-B services for situational awareness. The FAA is in the early stages of investigating a portable device for glider aircraft."


Clear as daylight.

 

[Jim Logajan]

Is have a bridge I can sell you......

I think Don is living in an alternative universe from the rest of us and the FAA.

While I like the idea of Skyguard and at one point purchased one, only to return it 2 days later, I strongly believe that the FAA will not allow ANY portable OUT units.

Same goes for the PADS unit.

I don't understand your anger and constant harping on Don - did you or did you not get your money back? He was the first one to attempt to build a unit that was reasonably affordable and usable immediately to renters.

At this point we have two manufacturers selling portable units that presumably will have non-zero SIL and then there is you and some self-appointed Internet Experts claiming or implying that they are essentially lying.

 

[Scrabo]

I don't understand your anger and constant harping on Don - did you or did you not get your money back? He was the first one to attempt to build a unit that was reasonably affordable and usable immediately to renters.

At this point we have two manufacturers selling portable units that presumably will have non-zero SIL and then there is you and some self-appointed Internet Experts claiming or implying that they are essentially lying.

My issue with Don and others, is that they continue to dangle the carrot regarding the FAA "pending" approval. Go and read his forums, it has been promised for years.

Yes I got the money back but how many other people are totally unaware that come 1/4/16 their $1400 unit is just a receiver.

While the split $100 upgrade is a nice gesture, it's just a bigger carrot.

 

[SportPilotCO]

This was in the AOPA group on Facebook as well. It seems pretty clear from the FAA here https://www.faa.gov/nextgen/equipadsb/faq/

"Why are portable ADS-B devices not allowed?

Portable ADS-B Out systems, also known as "suitcase" units, should not be operated (transmitting) aboard any aircraft. While marketing associated with these units may imply approval for use by way of an FCC license, the FAA prohibits their use for the following reasons:

The positioning of portable, suction-cup GPS antennas associated with these units often require they be affixed to front or side windows or glare shield to obtain a usable signal. Such antenna placement obstructs the pilot's view. Connecting wiring also interferes with aircraft controls and instruments.
ADS-B Out avionics require a valid Mode S code to be transmitted to operate properly with ATC automation and other ADS-B aircraft. Mode S codes, also known as the ICAO code, are assigned to an aircraft during registration and then programmed into transponders and ADS-B Out avionics. Mode S codes remain static until a change in aircraft registration or identification (N-number) occurs. Portable units require users to input the Mode S code assigned to each aircraft flown. A high number of Mode S code entry errors have occurred with this procedure, which prevent proper target correlation within ATC automation systems (target drops/traffic conflict alerts), which have resulted in increased workload and unnecessary distractions for pilots and controllers.
The positioning of ADS-B antenna is also vital in the quality of the signal that is transmitted, and if capable, received by the ADS-B device. There have been a number of aircraft identified using portable ADS-B devices that result in degraded performance due solely to poor antenna location."

 

[RotorDude]

This was in the AOPA group on Facebook as well. It seems pretty clear from the FAA here https://www.faa.gov/nextgen/equipadsb/faq/

"Why are portable ADS-B devices not allowed?

Portable ADS-B Out systems, also known as "suitcase" units, should not be operated (transmitting) aboard any aircraft. While marketing associated with these units may imply approval for use by way of an FCC license, the FAA prohibits their use for the following reasons:

The positioning of portable, suction-cup GPS antennas associated with these units often require they be affixed to front or side windows or glare shield to obtain a usable signal. Such antenna placement obstructs the pilot's view. Connecting wiring also interferes with aircraft controls and instruments.
ADS-B Out avionics require a valid Mode S code to be transmitted to operate properly with ATC automation and other ADS-B aircraft. Mode S codes, also known as the ICAO code, are assigned to an aircraft during registration and then programmed into transponders and ADS-B Out avionics. Mode S codes remain static until a change in aircraft registration or identification (N-number) occurs. Portable units require users to input the Mode S code assigned to each aircraft flown. A high number of Mode S code entry errors have occurred with this procedure, which prevent proper target correlation within ATC automation systems (target drops/traffic conflict alerts), which have resulted in increased workload and unnecessary distractions for pilots and controllers.
The positioning of ADS-B antenna is also vital in the quality of the signal that is transmitted, and if capable, received by the ADS-B device. There have been a number of aircraft identified using portable ADS-B devices that result in degraded performance due solely to poor antenna location."

So SkyGuard's official message to its customers is a lie?

After much discussion, the FAA is going to allow us to use an “alternate” GPS position source where we can set the SDA and SIL parameters to numbers greater than zero but NOT as a fully TSO’d position source. This GPS is “rule compliant” with 5hz position updates and will support both an internal active antenna as well as an externally mounted active antenna. This will allow our units to continue to receive TIS-B traffic client services after the enacted policy change.

And presumably the factory "upgrade to compliance" program for their customer base is a sham?

 

[Jim Logajan]

So SkyGuard's official message to its customers is a lie?

Again, the FAA has no authority over the radio spectrum or portable electronic devices along the lines they imply. Look closely at the reasons the author of that article claims they can prohibit the portable devices and consider that the reasons could be applied to a lot of other things pilots routinely do. No federally approved rule making procedures back them up, anyway.

Or more succinctly: the owners and users of these portable units are easily determined, yet other than threats and claims, the FAA has taken no action against any or those people. Why do you suppose that is?

 

[German guy]

[...] And presumably the factory "upgrade to compliance" program for their customer base is a sham?

I heard that the 'upgrade' will include a kit to permanently install it, in order to make it compliant.

I never was directly in contact with the seller, though.

 

[RotorDude]

Again, the FAA has no authority over the radio spectrum or portable electronic devices along the lines they imply. Look closely at the reasons the author of that article claims they can prohibit the portable devices and consider that the reasons could be applied to a lot of other things pilots routinely do. No federally approved rule making procedures back them up, anyway.

Or more succinctly: the owners and users of these portable units are easily determined, yet other than threats and claims, the FAA has taken no action against any or those people. Why do you suppose that is?

The FAA clearly can configure the ground stations to ignore SIL=0 downlinks, which would effectively disable the devices. That action would be more powerful than any other, since it would instantly destroy the SkyGuard company and render the installed equipment (hundreds of units, IIRC) into conversation pieces.
The question is: is there, as SkyGuard claims FAA has told them, some non-zero SIL value that means "not fully compliant, but we'll allow it as client", or not?
And if the answer is no, SkyGuard just made that up, why go through the sham of an extensive (and presumably expensive) factory upgrade program?

 

[Jim Logajan]

The FAA clearly can configure the ground stations to ignore SIL=0 downlinks, which would effectively disable the devices. That action would be more powerful than any other, since it would instantly destroy the SkyGuard company and render the installed equipment (hundreds of units, IIRC) into conversation pieces.

Not that extreme because those units also contain receivers that would still work and also because the transmissions, if enabled, would be visible to ADS-B receivers in nearby aircraft whose receivers do not filter such transmissions.

The question is: is there, as SkyGuard claims FAA has told them, some non-zero SIL value that means "not fully compliant, but we'll allow it as client", or not?
And if the answer is no, SkyGuard just made that up, why go through the sham of an extensive (and presumably expensive) factory upgrade program?

Source Integrity Level (SIL) of 1, probably, because the SIL value ranges from 0 to 3 and a level of 3 is required. So yes, such intermediate values exist. See page A1-2 of this document for their meaning:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 20-165.pdf

 

[RotorDude]

Not that extreme because those units also contain receivers that would still work and also because the transmissions, if enabled, would be visible to ADS-B receivers in nearby aircraft whose receivers do not filter such transmissions.



Source Integrity Level (SIL) of 1, probably, because the SIL value ranges from 0 to 3 and a level of 3 is required. So yes, such intermediate values exist. See page A1-2 of this document for their meaning:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 20-165.pdf

Regarding receivers ("in"), I believe only some of the units contain receivers, others are pure transmitters ("out only").
And the document you link says that a "minimum SIL value of three must be transmitted to operate in airspace defined in 14 CFR § 91.225." So if it's SIL=1, presumably they would be disallowed from "mode C airspace" after 2020, but would the FAA allow them as ADS-B clients until that point?
If the latter is "yes", I can imagine many pilots electing to buy a low cost (<$1K) portable "out" solution that should work for almost 5 years, with a chance for an even longer reprieve. Am I missing something?

 

[Scrabo]

I think SkyGuards statement is dubious at best. If you read thru their forums there has been a constant dialog between Don and the FAA for some time and it appears just to be a he said ,she said thing.

 

[RotorDude]

I think SkyGuards statement is dubious at best. If you read thru their forums there has been a constant dialog between Don and the FAA for some time and it appears just to be a he said ,she said thing.

Maybe so, but I would think a factory recall program of the entire installed base to upgrade them into compliance can hardly be a "he said she said" thing, esp. if it's all a sham.

 

[Scrabo]

Only time will tell. I, for one, am not holding my breathe

 

[Jim Logajan]

Regarding receivers ("in"), I believe only some of the units contain receivers, others are pure transmitters ("out only").

Yes, those would be mostly toast.

And the document you link says that a "minimum SIL value of three must be transmitted to operate in airspace defined in 14 CFR § 91.225." So if it's SIL=1, presumably they would be disallowed from "mode C airspace" after 2020, but would the FAA allow them as ADS-B clients until that point?
If the latter is "yes", I can imagine many pilots electing to buy a low cost (<$1K) portable "out" solution that should work for almost 5 years, with a chance for an even longer reprieve. Am I missing something?

As best I can determine that is my understanding.

A good portion of assertions allegedly coming from the FAA regarding what is allowed for ADS-B transmitters does not appear to be supported by either their regulations or those in 47 CFR Part 87 (FCC Aviation Services).

I have had good service with SkyguardTWX. They promptly upgraded my unit at no cost (other than shipping) when I asked about a problem. They seem to be the victim of modest capitalization - pretty common for a startup.