Avidyne SynVis - General

As some of you may have heard already, we did (finally) receive TSO/STC approval for R9.3 and SynVis.  Thank you all for hanging in there.

You should coordinate with Avidyne Sales/Service and your local Avidyne Service Center for the logistics of getting your airplane updated.

 

As for Garmin being subjected to the same rigor/scrutiny, I think the basic answer is yes.   There are always minor differences from ACO to ACO but at the macro level, I'd say it's a wash.  In fact Garmin often challenge something they think Avidyne "has gotten away with" and we do the same.   For better or worse, that behavior polices a level playing field.

 

R9.3 TIA was completed without a hitch last week.   We had a face-to-face session with the FAA this past Monday (19 May) to sort out the approval delay.

 

The FAA remains hung up on two issues that are preventing issuance of the TSO/STC:

 

1.  They asked for another round of changes to the DO-254 documentation.   There were no actual product changes, just documentation changes that were requested.  We made this 3rd round of document changes and submitted that yesterday for their review.

 

2.  They now require a DO-200A LOA.   This is a letter of authorization vouching for the integrity of the nav data in the system.   When R9 was first certified, RNAV approaches like LPVs were not considered RNP approaches.  Over the last year or so, the FAA has redefined RNP to now include RNAV approaches.  So, that now means that the previously not applicable regs that governed RNP now apply to R9 and one of those requirements calls for this Type 2 LOA letter.   Can't tell you how frustrating this is but we are now cranking out the supporting data that allow issuance of the LOA.   We think this will take 5-6 weeks to get this approved.   If the stars align, it could go faster but there hasn't been any stellar alignment observed on this program to date and it's not inconceivable it will take even longer.  If there is a sliver of good news, the FAA has made it their goal to have this all behind us at or prior to Oshkosh.  So I would anchor current expectations around an Oshkosh TSO/STC date for R9.3.

(R9.3 and SynVis Cert Update - 8 Apr 2014)

The latest roadblock in the saga was an FAA issue with the DO-254 cert documents.  It would appear that this issue (they wanted a different set of documentation) should be resolved to their satisfaction some time this week.  As soon as that is resolved, they have pre-authorized TIA to begin.

The FAA has completely delegated TIA back to Avidyne so that formal flight testing should start next week, presuming the DO-254 data is accepted this week.   That should last about a calendar week after which it's just a matter of the FAA signing the STC/TSO approval letters.

We had an unexpected but welcome visit today from the FAA who spent a few hours in our lab "flying" SynVis.   These were the flight test guys who are just one part of the full FAA cert team.

Nevertheless, that visit was very helpful in that they officially closed out all open human factors MPSUE issues - there had been 12 left open that were going to be evaluated during TIA flights.

They are also talking (I emphasize talking only - no actual decision has been made yet) about delegating all TIA back to us.  That has become a lot easier for them to do with the closure of the MPSUE items that were supposed to be evaluated by the FAA during TIA.

On the continued disappointing news front, there has been zero progress on the DO-254 compliance issue the FAA has raised.   We're working with them to unblock that log jam but so far, no dice.  I will say this issue appears to reside entirely within the FAA.   We're trying to figure this one out.

About an hour ago, we finished the work that we understood we had to add.  We're now trying to schedule a session with the ACO to walk our way through this new material with them to see if it meets their new expectations.

Garmin and Aspen use different offices from us and from each other.  Both are subjected to the same kind of thing at times.   Garmin has programs going for years before the public is aware.  Aspen and Avidyne elect to inform the public of products/programs when they start.   All have cert challenges.

What most people don't realize is that there are multiple FAAs.  Each region of the US is covered by a different certification office and they can, and sometimes do, apply different standards to applicants.  This is clearly not the intent of the FAA and they have some mechanisms in place to minimize the likelihood but in practice, it's not foolproof and this is definitely and example of that. 

We're still working out the true impact of this new requirement on the cert date.  It's a non-trivial undertaking.

This is release 9.3 correct?

Will this also include activation of the MLX unit for in flight weather here in Europe?

The Boston office is maxed out and Avidyne (and I  think others) are on the short end of that stick.  Combined with end of year (use or lose) vacation status for the FAA and normal holidays, I am not optimistic we'll see approval before the end of the year. 

The ACO has flat out told us they won't likely even start servicing the project until Jan.   I suppose a Christmas miracle is possible but I believe it is extremely unlikely.   

We've been ready for weeks and weeks and turned in our data a long time ago.  And still we wait.

Let me be clear it is not a lack of desire on their part, just a result of some internal prioritization that we are unable to influence in a meaningful way.

This has reached a point of extreme frustration.

What further aggravates the situation is the 8.33 kHz spacing mandate in Europe that takes effect on/about 1 Jan.  R9.3 has the 8.33 support and while the FAA has frequently acknowledged they understand the deadline and the motivation to get 9.3 approved, I am not optimistic that even that will influence approval dates.

Wish I had happier news.