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.

 

[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.

 

[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.

 

[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?

 

[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

 

[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.