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Garmin G3X Combining Certified with Experimental Models

This is a bit interesting when reading Part-NCO. Obviously the aircraft manufacturers have been thinking. NCO.IDE.A.100:

(a) Instruments and equipment required by this Subpart shall be approved in accordance with the
applicable airworthiness requirements if they are:
(1) used by the flight crew to control the flight path;
(2) used to comply with NCO.IDE.A.190;
(3) used to comply with NCO.IDE.A.195; or
(4) installed in the aeroplane.

But later in (c)

(c) Instruments and equipment not required by this Subpart as well as any other equipment that is
not required by other applicable Annexes, but is carried on a flight, shall comply with the
following:
(1) the information provided by these instruments or equipment shall not be used by the
flight crew to comply with Annex I to Regulation (EC) No 216/2008 or NCO.IDE.A.190 and
NCO.IDE.A.195; and
(2) the instruments and equipment shall not affect the airworthiness of the aeroplane, even
in the case of failures or malfunction.

The related GM:

GM1 NCO.IDE.A.100(c) Instruments and equipment — general
NOT REQUIRED INSTRUMENTS AND EQUIPMENT THAT DO NOT NEED TO BE APPROVED IN
ACCORDANCE WITH THE APPLICABLE AIRWORTHINESS REQUIREMENTS, BUT ARE CARRIED ON A
FLIGHT
(a) The provision of this paragraph does not exempt any installed instrument or item of equipment
from complying with the applicable airworthiness requirements. In this case, the installation
should be approved as required in the applicable airworthiness requirements and should comply
with the applicable Certification Specifications.

It all ends up in a reversed catch 22 kind of situation. The (uncertified) G3X is NOT an equipment in need of complying to any airworthiness requirements, simply because it doesn’t (and never will, being uncertified). The only requirement is in case of malfunction: It shall not adversely affect safety or airworthiness of the aircraft.

For VFR this is no problem as long as the aircraft has certified equipment as listed in NCO.IDE.A.120. Likevise for IFR: NCO.IDE.A.125. However, for IFR there is also (a)(3). Together (100 and 195) defines IFR nav equipment to be certified. Still, if you are able to navigate after that equipment, it doesn’t prohibit the use of an uncertified G3X + a GTN 650 or similar. If this is a better/cheaper solution that a fully certified flight deck? I have no idea. It probably may, and may not depending on the aircraft.

The elephant is the circulation
ENVA ENOP ENMO, Norway

dvukovic wrote:

I could save some extra money on the EIS option as well by connecting it to the experimental G3X

Exactly. Today, Garmin do indeed sell certified versions of the G3X. In the P2008, the uncertified G3X could be replaced by a certified G3X and the small certified combined HSI/ASI/Alt could be removed entirely. But:

  • At what cost?
  • For what purpose? (you essentially lose you “backup” primary flight instruments)

A certified G3X sounds nicer on the paper than in reality IMO.

I have no idea if they talk with each other though, the certified and uncertified version.

The elephant is the circulation
ENVA ENOP ENMO, Norway

@LeSving: That is my idea as well, have a certified G3X + G5 and show only that officially, and on the other hand have two experimental G3X’s just for a “situational awareness”… And if those can communicate between themselves, I could save some extra money on the EIS option as well by connecting it to the experimental G3X.

Belgrade LYBE, Serbia

Peter wrote:

can approve items under the Type Certificate

I think you miss the point. The G3X touch in the Tecnam is as uncertified as ever. There is nothing “approved” about it, in a certified sense. It’s simply a “situational awareness device”, exactly as a moving map on a tablet. This is a warning that is littered throughout the manual:

The small certified combined ASI, ALT, HSI instruments is more of an “excuse”. No one looks at those instrument unless the G3X goes black. Thus the real function is obviously as a backup. Still, no one can deny that the aircraft has fully certified primary instruments (it’s actually a nice little piece).

In essence, the G3X is furniture, empty panel space, or whatever you like to call it. I don’t see how this is different in a CS-VLA than in a CS-23. The point according to regulations is to have a set of certified primary flight and navigation instruments, period. As long as this requirement is fulfilled, you can do whatever you want to:

  • increase situational awareness
  • build your panel so it is structurally sound

That’s my take on it.

The elephant is the circulation
ENVA ENOP ENMO, Norway

@LeSving: Just the fact that its VLA/LSA makes it a completely different problem, as far as I am aware with VLA/LSA you can do pretty much whatever you want (compared to GA aircraft maintenance requirements).

My idea is to do this combination in A36 Bonanza and basically just get one extra G3X 10" display, if I choose to buy second one experimental instead of certified. I would definitely not like to trade IFR capabilities just to have a fancy display, so I am looking for a way if this could be done legally.

Belgrade LYBE, Serbia

Various previous threads e.g. here on uncertified avionics in certified aircraft.

There is some route whereby the manufacturer / TC holder (who is invariably an EASA 21 and EASA145 company, wih a special relationship with EASA) can approve items under the Type Certificate. In the FAA system the company has an in house DER and is FAA145 which is the sort of equivalent system.

It is also a lot easier for VFR only.

Even for fully IFR Part 23 aircraft, for example Socata buy in loads of normal commercial parts, and parts from various companies serving the homebuilt market, and they certify them under their own authority.

Doing this as an aircraft owner is a lot harder.

Administrator
Shoreham EGKA, United Kingdom

I must say I was surprised about the instruments and instrument panel of the club’s brand new P2008. It’s certified as EASA VLA, VFR night.

It has a non certified G3X touch, two screens. A GTX-335 transponder and a GNC-255A nav/com and a VOR antenna. Between the two screens is a tiny digital altitude and airspeed indicator as well as a digital artificial horizon. These three are the primary instruments, the G3X is only for “situational awareness”. The GNC has NAV apparently, but I haven’t figured out how to use it yet with the G3X. GPS is obviously the primary navigational instrument (for “situational awareness only” )

To me this looks exactly like a setup on an experimental plane, go figure.

The elephant is the circulation
ENVA ENOP ENMO, Norway

I heard that you can purchase a G5 with STC documents and another one from the experimental world and you would have the ability to install the 2 devices under the STC coming from the first one. Now, that’s in FAA world and that could be specific to the G5 and not applicable to the G3X.

Belgium

No chance. The experimental parts won’t come with a Form 1 and don’t fall into 21A307c for acceptance without a release certificate.
Garmin will probably also have different software in the certified version.

Avionics geek.
Somewhere remote in Devon, UK.

I don’t think that G3X can be classified solely as GNSS equipment, its a full flight deck. But anyways this document would open much more questions than it answers, I was hoping for a quick answer from somebody with experience in a similar situation.

Belgrade LYBE, Serbia
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