ADS-B Policy Memo Guidance

ADS-B Policy Memo Guidance

What if my aircraft is not on the AML?

Good news! Under FAA Memo titled ” Installation Approval for ADS-B OUT Systems,” the FAA explains that after an STC is achieved for ADS-B OUT equipment, additional installations can be accomplished with an A&P with Inspection Authorization (IA) so long as the installation does not require airframe modification. This process requires completion of a form called FAA Form 337MAJOR REPAIR AND ALTERATION. We are providing guidance with a sample skyBeacon Form 337 here and tailBeacon Form 337 here .  For more detailed information on the FAA memo please read below.

Here is the relevant portion from the FAA memo regarding installation of ADS-B on aircraft not covered by the device STC AML.  

After initial approval, can applicable ADS-B OUT systems be installed on aircraft not covered by that approval? 

Yes, ADS-B OUT systems that have previously received FAA approval and meet all of the following conditions may be installed and returned to service on other aircraft without further data approval.

 You can read the memo for the conditions but they are all met by the skyBeacon.  It has the required TSOs and an AML STC.  The FAA created this policy to improve equipage rates as there are hundreds of aircraft models not covered by current STCs for ADS-B equipment.  We've provided excerpts from the memo below with our comments regarding how skyBeacon meets the required conditions.


The items below are taken starting from page 3 of the memorandum.  It has become a commonplace method to approve ADS-B installs.  If you refer to the Garmin approval for the GDL-82 the STC only applies to the Mooney M20, yet the device is being installed on airframes not covered by the STC using process outlined below.

After initial approval, can applicable ADS-B OUT systems be installed on aircraft not covered by that approval? 

Yes, ADS-B OUT systems that have previously received FAA approval and meet all of the following conditions may be installed and returned to service on other aircraft without further data approval: 

Note: If an Approved Model List (AML) STC is available that provides for the installation of specific ADS-B transmitter and GPS pairings on listed aircraft. consider using the data from that AML STC "for the ADS-B OUT system installation. 

2 Note: Some elements of an ADS-B OUT installation may not meet the definition of a minor alteration. such as the installation of antenna(s) that penetrate a pressure vessel. Such installation elements may require additional data from the aircraft manufacturer or other FAA approved data. Reference Attachment 1 of this memorandum, ADS-BOUT Alteration Flowchart tor guidance on determining the eligibility of ADS-BOUT installations covered by this policy. 

On most aircraft skyBeacon requires zero modification to the airframe and no penetration of any pressure vessel. skyBeacon uses the existing wiring and screw mounting locations made available by removing the position light.  

a. The ADS-B OUT equipment is manufactured under TSO-C 166b or TSO-C 154c; 

skyBeacon is approved as a TSO-C154c device which satisfies section A.

b. The Global Navigation Satellite System (GNSS) position sensor is manufactured under TSO-C129 or later, TSO-C145a/C146a or later, or TSO-Cl96 or later; 

skyBeacon's integrated GPS is approved as TSO C145D Class Beta 1 satisfying section B.


c. The installer has a statement of compliance from the applicable manufacturer(s) or STC holder that the equipment (self-contained) or specific equipment pairing (ADS-B OUT transmitter and GNSS position sensor) have been shown, via TC, Amended TC, or STC, to comply with all section 91.227 requirements. This statement of compliance may be included in the applicable installation instructions. The installation instructions must address how the equipment is to be installed and maintained to comply with not only the applicable TSOs but also section 91.227 requirements; 

skyBeacon will arrive with a Certificate of Conformance, the TSO and STC manuals provide the data and approval information and installation data.  The skyBeacon GPS/transmitter is self-contained and so there is only one equipment pairing to approve/comply with section C.  The AML STC represents FAA and manufacturer approval of that pairing.  

d. The installer has documentation from the STC holder(s) (per section 91.403( d)) that indicates the owner/operator of the aircraft has permission to use the STC data tor the alteration;  

Our permission letter is available here for your use to satisfy section D:  https://uavionix.com/downloads/skybeacon/skyBeacon-Permission-to-Use-STC-UAV-1002113-001.pdf

e. The ADS-BOUT equipment, GNSS position sensor, and interconnect wiring are connected in accordance with the applicable manufacturer's or STC installation instructions; 



f. The installation is performed in accordance with documentation from the manufacturer(s) or STC holder indicating what configuration settings. if applicable, are to be used for the ADS-BOUT system to meet section 91.227 requirements which include. but may not be limited to: (I) FAA assigned Mode S/International Civil A vi at ion Organization (ICAO) code address (hexadecimal/octal format) associated with current aircraft registration; (2) Emitter Category (ref. AC 20-165. Chapter 3); (3) System Integrity Level (SIL); (4) System Design Assurance (SDA); (5) Flight Identification (e.g., N-number); and (6) GNSS sensor settings required to correctly communicate with the ADS-8 OUT equipment 

Refer to our TSO or STC manual as appropriate to satisfy section F:   

g. The installation is performed in accordance with 14 CFR Part 43. Acceptable methods, techniques, and practices may be found in AC 43.13-28; 

As with any installation, it is up to the installer to complete and use approved best practices to satisfy section G.

h. The installed ADS-BOUT system has been verified to comply with both the system configuration and equipment performance requirements of section 91.227. The system configuration aspects of section 91.227 requirements include the ICAO code address, emitter category, SIL, SDA, flight identification, etc. Performance aspects of section 91.227 requirements include Navigation Integrity Category (NIC), Navigation Accuracy Category for Position and Velocity (NACp and NACv), etc. Acceptable compliance verification methods include: 

Per the memo two different ways can be used to verify performance.  The first method is to fly the aircraft according to the FAA flight requirements.  In summary the aircraft must be flown in "rule airspace" as defined in 14 CFR 91.225 for a minimum of 30 minutes with at least 10 aggregate minutes of maneuvering (AC 20-165B contains flight maneuver recommendations).  There is no requirement to schedule or notify ATC of the performance validation flight at this time.  

(I) Operational Flight Evaluation. Conduct an operational flight evaluation (OFE) per section 91.407(b) and request an FAA ADS-B compliance report at the following email address 9-AVA-AFS-300-ADSB-AvionicsCheck@faa.gov Include the aircrart·s registration number (N-number) and the ADS-B transmitter and GPS equipment make/model information when submitting requests to the FAA for ADS-B OUT system OFE performance checks. Following receipt of the applicable OFE compliance report the installer must verify the installed ADS-BOUT system complies with all section 91.227 performance requirements and the system configuration is correct for the aircraft.

In lieu of directly contacting the Avionics Check via email the FAA has established a webpage for requesting the basic validation report:  
https://adsbperformance.faa.gov/PAPRRequest.aspx

In order to request a report the pilot or installer should choose:
ADS-B OUT Data Link: UAT
Under Enter UAT Transmitter:
Manufacturer: uAvionix
Model:  skyBeacon TSO

The second option is to use an ADS-B test set to verify the performance of the skyBeacon.

(2) Ramp Test Equipment (ref. section 91.407(c)). Use ramp test equipment to verify proper system configuration and compliance with section 91.227 equipment performance requirements. 1. The ADS-B OUT alteration must be documented in the aircraft maintenance record per section 43.9(a) and include the statement, ·'The installed ADS-BOUT system was shown to meet the equipment performance requirements of 14 CFR section 91.227." 

Submit a FAA Form 337 to document ADS-BOUT alterations. On Form 337, Block 8, include the following compliance statement, "The installed ADS-BOUT system was shown to meet the equipment performance requirements of 14 CFR section 91.22T along with the applicable ADS-B OUT transmitter and GPS make/model information. Submit the completed Form 337 to the Aircraft Registration Branch, AFS-750, P.O. Box 25504, Oklahoma City, Oklahoma 73125. The Form 337 can be submitted directly without FAA approval in Block 3.

As indicated in the memo and highlighted above Block 3 does not need to be completed or approved by an FAA representative prior installation or submission.  A sample Form 337 is available from this location:  https://uavionix.com/downloads/skybeacon/Sample_skyBeacon_337_form-Rev-D.pdf

In summary, the guidance outlined above comes directly from the FAA and the ADS-B team and has been used by Appareo, Garmin, Freeflight, L3, as a common method to approve and install ADS-B systems in thousands of aircraft not covered by an STC.  As per the FAA guidance, there is no field approval or FSDO involvement required if the device meets the criteria as outlined in the memo which skyBeacon does.

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