(4) AC 25-4, Inertial Navigation Systems.
b. This AC supersedes the airworthiness considerations in AC 90-45A, Approval of Area Navigation Systems for use in the U.S. National Airspace System. Equipment previously approved per the airworthiness guidance in AC 90-45A is still valid for the operations and conditions stated in their approvals.
1-4. Frequently Asked Questions.
This paragraph contains a list of questions concerning the guidance material in this AC.
The responses to these questions are intended to help applicants interpret the guidance contained in this AC.
a. Ground Proximity Warning System/Terrain Awareness and Warning System (GPWS/TAWS) Mode 5 alert.
(1) Question: Is a GPWS or Class A TAWS Mode 5 alert a hard requirement to add localizer performance with vertical guidance (LPV) or GBAS landing system (GLS) capability?
(2) Answer: No. It is not the FAA’s intent to burden manufacturers and operators by changing the GPWS or TAWS functions. The intent is simply to recommend a glidepath alerting function to help prevent controlled flight into terrain during LPV, LNAV/VNAV, and GLS approaches. See paragraphs 15-7.8 and 15-9.13 for clarification and additional guidance.
b. Class B TAWS and LPV or GLS Capability.
(1) Question: Is a low glideslope alerting function for LPV or GLS required with Class B TAWS for compliance with the guidance in paragraphs 15-7.8 and 15-9.13?
(2) Answer: No. It is not the FAA’s intent to burden manufacturers and operators by changing the GPWS or TAWS functions. The intent is to simply recommend a glidepath alerting function to help prevent controlled flight into terrain during LPV, LNAV/VNAV, and GLS approaches.
c. Using the term vertical navigation (VNAV).
(1) Question: Doesn’t RTCA/DO-229D assign a very specific meaning to the term ‘VNAV’ and dictate the term’s specific uses for SBAS-based vertical navigation?
(2) Answer: No. RTCA/DO-229D, section 2.2.1.1.7 provides a recommended usage for the ‘VNAV’ label, but only requires that the label be used in a consistent manner.
‘VNAV’ can be used for an LNAV/VNAV approach procedure generated by GPS/SBAS-based or barometric-based vertical navigation capability (GPS/GBAS does not provide an LNAV/VNAV approach capability). The ‘VNAV’ label can also be used for an advisory vertical navigation function that provides vertical path deviation guidance indications on a 3
non-essential, not-required basis. Refer to the following AC 20-138D, chapters for additional information:
• Chapter 4, Advisory Vertical Guidance;
• Chapter 11, Baro-VNAV;
• Chapter 12, section 12-11, General Human Factors Considerations;
• Chapter 15, section 15-7.6, GPS/SBAS Equipment Annunciations; and,
• Chapter 18, section 18-5, Baro-VNAV integration with GNSS-Provided Vertical Guidance.
d. Tightly-coupled inertial navigation system/global positioning system (INS/GPS).
(1) Question: AC 20-138D, section 6-7 c. includes the following statement: "The FAA assumes that there is a limitation on the use of the GPS/inertial position data output to support enroute through lateral navigation (LNAV) approach only." Can you please explain the basis of this assumption? It appears to exclude the use of tightly coupled INS/GPS for oceanic use. Is this the intent? Or, is the intent to exclude it for use for LPV?
(2) Answer: Paragraph 6-6 addresses loosely-coupled systems and paragraph 6-7 addresses tightly-coupled systems. There is no intent to exclude either loosely-coupled or tightly-coupled INS/GPS from oceanic use. However, un-augmented GPS, even with tightlycoupled INS, is not adequate for vertical approach capability, and hybrid inertial vertical approach capability is not addressed in RTCA/DO-229D, appendix R. As stated in this AC, a GPS-based vertical approach capability requires GPS/SBAS or GPS/GBAS augmentation.
e. Flight management system (FMS) limitations.
(1) Question: AC 20-130A, section 5.d.(2) contained a limitation on FMS use and required an alternate means of navigation for the route flown. AC 20-138D does not include this section or make a mention of this limitation. What was the reasoning behind not including a similar section in AC 20-138D? Is there some higher level guidance that addresses this or is it left up to the safety analysis to address the need for an alternate means of navigation?
(2) Answer: It is important to differentiate between operational limitations and equipment performance limitations. AC 20-138D addresses equipment performance limitations while the 90-series ACs produced by Flight Standards address operational limitations (for example, 90-100, 90-101A, 90-105 for RNAV, RNP AR, and RNP respectively) as well as the Aeronautical Information Manual and operational rules (parts 91, 121, 135).
(a) AC 20-130A was written prior to implementing performance-based navigation concepts and the evolving RNAV/RNP-based National Airspace System. An FMS incorporating multiple navigation sensor inputs by its very nature has multiple sources of navigation, but the individual sensors have performance limitations on their navigation capabilities. Accordingly, the FMS functions will meet different requirements depending upon the sensors involved and the intended navigation capability. This AC addresses the performance limitations of the individual sensors contained in the document. These performance limitations 4
must be considered for the overall intended function at the aircraft level during the airworthiness approval (i.e., during the type certificate (TC), amended type certificate (ATC), or supplemental type certificate (STC) approval) to determine any limitations on the aircraft.
(b) In summary, operational rules dictate the navigation equipage requirements. It is up to the operator to determine how to comply based on their specific operating rules and mission needs.
f. Satellite Navigation Terminology.
(1) Question: Why are so many different names and acronyms (such as GNSS, WAAS, SBAS, etc.) used for GPS?
(2) Answer: The different names and acronyms used depend upon whether the topic is a generic, international reference to satellite navigation, or a particular State’s specific implementation.
(a) GNSS is used internationally to indicate any satellite-based positioning system or augmentation system. The acronym ‘GNSS’ includes satellite constellations, such as GPS, GLONASS, Galileo, or Beidou, along with augmentation systems such as ‘SBAS’ and ‘GBAS’; all of which provide a satellite-based positioning service.
(b) The acronyms ‘SBAS’ and ‘GBAS’ are the respective international designations for satellite-based and ground-based augmentation systems complying with the International Civil Aviation Organization (ICAO) standards and recommended practices (SARPs). Several countries have implemented their own versions of ‘SBAS’ and ‘GBAS’ that have specific names and acronyms. For example, WAAS is the U.S. implementation of an ‘SBAS’ while EGNOS is the European implementation. Refer to Appendix 9 for definitions of terms and acronyms.
Note: This AC uses the acronyms GPS/SBAS and GPS/GBAS throughout for consistency and clarity to indicate augmentation systems for the GPS constellation.
g. RNAV versus RNP.
(1) Question: Are technical standard order (TSO)-C129(AR) Class A1 GPS and TSO-C146(AR) Class Gamma GPS/SBAS equipment RNAV or RNP systems?
(2) Answer: Both. RNAV systems conform to the ICAO performance-based navigation specification for total system error (TSE). RNAV total system error is the 95% probability that the navigation system accuracy remains within the limits defined for the RNAV operation. For example, during an RNAV-1 operation the TSE remains within one nautical mile of the desired path 95% of the time (see Figure 1 below). RNP systems conform to a performance-based navigation specification based on RNAV capability that also includes requirements for on-board performance monitoring and alerting. For example, during an RNP 5
1 Nautical Mile 95% of flight time --T-rack Centerline~ 1 Nautical Mile 95% of flight time 4/7/16 AC 20-138D Change 2
1.0 operation, the TSE remains within one nautical mile of the desired path 95% of the time, and on-board performance monitoring provides the pilot with an alert when the probability that TSE exceeds 2xRNP is greater than 10-5 (see Figure 2 below). RNP is an RNAV subset that also includes a requirement to provide on-board navigation system accuracy performance monitoring and alerting which means an RNP system is also an RNAV system. GNSS equipment provides accuracy performance monitoring and alerting which, by definition, makes it both an RNAV and RNP capable system.
Note: TSO-C129(AR) Class B/C, TSO-C145(AR), and TSO-C196(AR) sensors provide both RNAV and RNP capability when interfaced to an appropriate navigation computer (such as TSO-C115d).
(a) By definition, TSO-C129(AR) Class A1 and all TSO-C146(AR) Class Gamma GNSS equipment provides an RNAV capability that includes on-board performance monitoring and alerting. This equipment has the capability to perform RNAV(GPS) approaches to at least the LNAV line of minima.
(b) RNAV(GPS) approaches require GPS, which includes on-board performance monitoring and alerting. Therefore, an RNAV(GPS) approach is an RNP procedure where the initial, intermediate, and missed approach segments are RNP 1.0. The LNAV final approach segment is RNP 0.3.
(c) None of the preceding statements should be confused with RNP AR that requires special aircraft and aircrew approval. Neither TSO-C129(AR) Class A1 GPS nor TSO-C146(AR) Class Gamma GPS/SBAS can qualify for RNP AR operations without additional aircraft and aircrew approvals (see appendix 2). No RNP AR procedures can be included in the navigation databases of equipment that is not approved for RNP AR operations.
RNP AR approach procedures are titled RNAV(RNP) and have an “authorization required” designation printed on the charts.
Figure 1. RNAV Depiction 6
RNP 1 RNP 1 Alert to Pilot ne Track Centerline 1 N ne 1 Nautical Mile 95% of flight time 1 Nautical Mile 95% of flight time Track Centerline 1 Nautical Mile 99.999% of flight time 1 Nautical Mile 99.999% of flight time The Key Difference:
On -board Performance Monitoring and Alerting Figure 2. RNP Depiction
h. Incomplete Technical Standard Order (TSO).
(1) Question: Is it possible to receive an incomplete TSOA for a GPS or GPS/SBAS receiver circuit card assembly providing the functional performance of a sensor unit?
(2) Answer: No. The basis for a TSOA is that the applicant has sufficient control over the design and production to assure the system meets the minimum performance standard published by the FAA. However, we do allow for incomplete systems to obtain an authorization, as explained in the latest revision of AC 21-46, Technical Standard Order Program.
(a) The incomplete authorizations are applicable to a complete unit that performs a subset of the required performance or functionality of the TSO (see AC 21-46 (latest revision), paragraph 5-3). A GNSS receiver circuit card assembly is not a complete unit; it is a part that must be incorporated into another box to function properly. AC 20-170 (latest revision) Integrated Modular Avionics Development, Verification, Integration, and Approval Using 7
RTCA/DO-297 and Technical Standard Order-C153, addresses a somewhat similar situation for integrated modular avionics (IMA). But, navigation and non-navigation avionics equipment that incorporate GNSS receiver circuit card assemblies are not an IMA. Therefore, the IMA guidance is not applicable.
(b) However, the FAA recognizes that GNSS receiver circuit card assemblies are more than “component parts” and fundamentally provide the GNSS sensor functional capability. In essence, the only difference between a complete GNSS sensor unit and a receiver circuit card assembly is the sensor unit includes a power supply and enclosure shielding. But this difference is significant relative to the performance tests in the minimum operational performance standard (MOPS) specified by the GNSS TSOs. The concern is that a bare receiver circuit card assembly could pass the MOPS performance testing in isolation, but not maintain that performance when integrated into another device where it might be exposed to significant radio frequency interference from other circuit card assemblies or devices. The FAA has created three new TSOs to address this concern and provide certification credit for the functional capabilities in GNSS receiver circuit card assemblies. But the GNSS receiver circuit card assembly’s end-user must repeat selected MOPS performance tests with the circuit card assembly installed in the end-use equipment and apply for the applicable GNSS sensor unit TSO (see paragraph 3-5).
i. Incorporating Step-down Fixes in Navigation Databases.
(1) Question: The latest ARINC 424 format has fields for both named and un named step-down fixes. Is it acceptable for equipment manufacturers to include approach procedure step-down fixes in the navigation database; particularly when LPV capability is included?
(2) Answer: Yes. But ARINC 424 is not a TSO-specified standard, so there is no “requirement” to include step-down fixes or use all the fields. Having step-down fixes in the navigation database can present challenges for the airworthiness approval when LPV capability is included since step-down fixes are not applicable to LPV and the LPV requirements are designed to mimic an instrument landing system (ILS). The airworthiness applicant must ensure there is no confusing or disparate information presented to flight crews due to the cockpit arrangement. This can be a significant issue in legacy cockpits that have limited display capabilities. See paragraph 12-8 for guidance when including step-down fixes in the navigation database.
j. Using RTCA Inc. document (RTCA)/(DO)-178C Software Considerations in Airborne Systems and Equipment Certification, dated December 13, 2011.
(1) Question: Is it acceptable for equipment manufacturers to use RTCA/DO-178C in lieu of RTCA/DO-178B?
(2) Answer: Yes. In the U.S. it is acceptable for software development to use revision ‘C’ for TSOs that specify revision ‘B’ thru the deviation process. The project ACOs may approve deviation requests to use revision ‘C’ in lieu of revision ‘B’ without Headquarters 8
coordination. Refer to AC 20-115C for additional guidance on software qualification, including re-using software qualified to previous RTCA/DO-178 revisions.
Chapter 2. Technical Standard Order Authorization (TSOA) and Airworthiness Approval Considerations - General.
2-1. Guidance for TSOA/Letter of Design Approval (LODA) and Airworthiness Approvals.
Title 14 CFR part 21; subparts D, E, and O provide the regulatory basis defining changes to TC (major/minor changes to aircraft type design), STC, and TSOAs. The regulations and TSOs can be found at: http://rgl.faa.gov. This chapter provides general guidance on TSOA/LODA and airworthiness approval considerations specific to positioning and navigation equipment.
2-2. TSOA.
a. Several TSOs are available for positioning and navigation-related equipment and components (see appendix 10 of this AC). New TSOs will be written to address modernized GPS and other GNSSs once appropriate equipment standards are in place. It is benefi cial to
involve the ACO (both engineers and flight test pilots) in equipment evaluations as early as
possible for four primary reasons:
(1) Obtaining a TSOA/LODA does not ensure that the equipment will satisfy all of the applicable operational requirements and/or airworthiness regulations when it is installed.
(2) Positioning and navigation equipment has become increasingly more complex and workload intensive with no standardized pilot interface. The human factors evaluation of the equipment can be subjective.
(3) There is no one, single standard for interfacing positioning and navigation equipment to other equipment on-board the aircraft such as displays, autopilots, and terrain
warning systems. Positioning and navigation equipment manufacturers should develop compatibility data relative to other equipment for inclusion within the installation manual.
(4) The installed intended function for the equipment needs to be compatible with the original design for the system, including software and hardware design assurance levels and data process assurance levels. For example: a decision by the positioning and navigation equipment manufacturer to develop system software to RTCA/DO-178B Level C, may limit installation eligibility if that equipment contributes to failure conditions of other systems that perform critical functions to a higher software design assurance level.
Note: AC 20-115C provides guidance on using RTCA/DO-178C including re-using software qualified to previous RTCA/DO-178 revisions.
b. It is recommended that the positioning and navigation equipment manufacturer elect to obtain an STC for equipment installation concurrent with obtaining the TSOA/LODA. This has proven to be an effective method to aid installations.
Note: Any applicant may apply for an equipment installation STC. It is not this paragraph’s intent to limit 10
positioning and navigation installation STCs solely to avionics manufacturers.
c. The installation manual and other data approved during the TSOA process can be used as a source of approved data to support an installation airworthiness compliance finding provided the data is applicable to the installation airworthiness requirements (see AC 21-50 (latest revision), Installation of TSOA Articles and LODA Appliances).
2-3. STC-Approved Model List (AML).
a. All STC applicants are encouraged to use an AML for aircraft makes/models (including 14 CFR parts 23, 25, 27, and 29 aircraft) with similar characteristics and compatible equipment configurations to streamline the approval of subsequent installations. Applicants and ACOs need to contact the applicable directorate for specific policy and guidance information on obtaining an STC-AML.
b. Using the STC-AML method can simplify follow-on installations for makes/models on the AML. T he installer needs access to the STC approved data; apply the approved data;
and comply with the detailed installation instructions. The installer then needs only complete FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, Appliance), identifying the nature of the change to return the aircraft to service (see AC 43.9-1 (latest revision), Instructions for Completion of FAA Form 337).
c. GPS and GPS/SBAS equipment airworthiness approval is not considered novel or unusual per 14 CFR 21.16 and applicants can use designees during the STC process.
2-4. Type Certificate.
Positioning and navigation equipment manufacturers are also encouraged to work with TC holders. This has also proven to be an effective method to aid installations.
Chapter 3. TSO Authorization.
3-1. TSO-C196(AR).
a. TSO-C196(AR), Airborne Supplemental Navigation Sensors for Global Positioning System Equipment Using Aircraft-Based Augmentation, defines an acceptable standard for GPS equipment without ground-based or space-based augmentations. The TSO has been updated to revision ‘b’ for harmonization with TSO-C129a’s cancellation and for TSO-C206 circuit card assemblies. TSO-C196(AR) is intended as the aircraft-based augmentation GPS sensor standard for TSOA/LODA applicants. TSO-C196(AR) equipment has a performance limitation that requires other positioning and navigation systems appropriate to the operation on-board the aircraft.
Note: TSO-C129a has been cancelled, but this does not affect equipment with an existing TSOA/LODA (see paragraph 3-1.c).
b. TSO-C196(AR) defines GPS sensor equipment that incorporates many processing improvements found in the GPS/SBAS equipment MOPS; but, without the GPS/SBAS requirements. Two improvement examples are: a requirement for the receiver to properly account for satellite range error if it is reflected in the User Range Accuracy index (commonly referred to as being “Selective Availability aware”), and requirements to ensure performance is not degraded due to an increasing radio frequency noise environment as other satellite systems become available.
(1) TSOA/LODA applicants may wish to have a previously approved TSO-C145b (or later revision), Airborne Navigation Sensors Using the Global Positioning System (GPS) Augmented by the Wide Area Augmentation System (WAAS), sensor approved as a TSO-C196b sensor. It is acceptable for TSO -C196b applicants to take certification credit by re-using data developed during a previous revision ‘b’ or later TSO-C145 TSOA/LODA approval. RTCA/DO-316, Minimum Operational Performance Standards for Global Positioning System/Aircraft-Based Augmentation System Airborne Equipment, dated April 14, 2009, implemented by TSO-C196(AR) was developed from RTCA/DO-229D, Minimum Operational Performance Standards for Global Positioning System/Wide Area Augmentation System (GPS/WAAS) Airborne Equipment, dated December 3, 2006, implemented by TSO C145b/c (revision ‘d’ implements RTCA/DO-229D, Change 1). Both RTCA/DO-229D and RTCA/DO-229D, Change 1 meets or exceeds the performance requirements for TSO-C196b.
The original RTCA/DO-178B or ‘C’ documentation can be re-used if there are no software changes.
(2) Applicants seeking a TSO-C196b TSOA/LODA based on a previously approved revision ‘b’ or later TSO-C145 sensor must maintain separate part numbers for each unit. It is not acceptable to have both a TSO-C145(AR) and TSO-C196(AR) TSOA/LODA simultaneously on the same article (see paragraph 3-6.b(4)).
Note: Maintaining separate part numbers might only require different software part numbers.
(3) It is acceptable for TSOA/LODA applicants with revision ‘b’ or later TSO-C145 sensors to simply disable the GPS/SBAS tracking loops in their equipment to apply for a TSO-C196b TSOA/LODA. The applicant will need to su pply substantiation that the SBAS tracking loops are permanently disabled along with the data from their revision ‘b’ or later TSO-C145 TSOA/LODA.
(4) TSOA/LODA applicants with TSO-C145a sensors will need to show requirements traceability between RTCA/DO-229C and RTCA/DO-316 along with data applicability to receive appropriate certification credit. In particular, applicants will need to show compliance to all RTCA/DO-316 requirements not addressed in RTCA/DO-229C, and requirements that are more stringent such as enroute/terminal mode accuracy and the broadband external interference noise environment.
c. TSO-C129a was cancelled effective October 21, 2011, but there is no plan to withdraw TSO-C129(AR) authorizations. TSO-C129a cancellation will not affect existing authorizations. Manufacturers can continue production according to their existing TSO-C129(AR) TSOA/LODA. Additionally, the equipment is still eligible for installation according to existing airworthiness approvals and is eligible to receive new airworthiness approvals.
(1) No new TSO-C129a TSOAs/LODAs will be granted.
(2) Major changes to an existing TSO-C129a equipment design will require a new application according to 14 CFR 21.619(b) for either TSO-C145d, TSO-C146d or TSO C196b.
3-2. TSO-C145(AR)/C146(AR).
a. TSO-C145d, Airborne Navigation Sensors Using the Global Positioning System (GPS) Augmented by the Satellite-Based Augmentation System (SBAS) and TSO-C146d, Stand- Alone Airborne Navigation Equipment Using the Global Positioning System (GPS) Augmented by the Satellite Based Augmentation System (SBAS) define an acceptable standard for GPS/SBAS equipment. There is no equipment performance limitation for GPS/SBAS equipped aircraft to have other positioning and navigation systems on-board.
Note: Refer to the appropriate operating rules and
operational guidance documents for equipage
requirements.
b. RTCA/DO-229D referenced by the GPS/SBAS TSOs will remain as the MOPS for single-frequency GPS/SBAS equipment. Future multi-frequency/multi-constellation equipment will have a separate MOPS and TSO.
c. There is no plan to withdraw authorizations to the earlier TSO revisions, so manufacturers of TSO-C145/C146 revision ‘a’ through ‘c’ equipment can continue production according to their TSOA/LODA; and the equipment is still eligible for installation in accordance with the guidance in this AC.
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d. The difference between revisions ‘b’ and ‘c’ to the GPS/SBAS TSOs is eliminating a 3 decibel (dB) broadband intra-system noise credit for operational Class 1 and Class 2 equipment in RTCA/DO-229D. TSO-C145b/C146b operational Class 3 and Class 4 equipment fully complies with the requirements in TSO-C145c/C146c and is automatically eligible for a revision ‘c’ authorization, i.e., no further evaluation is necessary.
e. The difference between revisions ‘c’ and ‘d’ to the GPS/SBAS TSOs is:
recognizing TSO-C204/C205 circuit card assemblies; and using Change 1 to RTCA/DO-229D.
f. TSO-C145b/C146b operational Class 1 and Class 2 equipment that did not claim the 3dB noise credit is also eligible for a revision ‘c’ authorization. The TSOA/LODA holder only needs to provide substantiation that they did not take the noise credit during the original certification.
g. Displays or navigation computers (such as FMSs) may receive a TSO-C146d Class 1, 2, or 3 (functional Class Gamma) incomplete TSOA/LODA provided they meet the applicable Class Gamma requirements in RTCA/DO-229D and are linked by part number to compatible TSO-C145(AR) sensors in the TSO application documentation. This is an effective method to aid GPS/SBAS installation approvals to make a complete system (sensor, navigation computer, display) at the aircraft level.
Note: See paragraph 3-4 for additional information on FMS incomplete TSO-C146c Class Gamma TSOA/LODAs and Class Delta-4 FMS implementations.
3-3. TSO-C161a/C162a.
a. TSO-C161a, Ground Based Augmentation System Positioning and Navigation Equipment, defines an acceptable standard for GPS/GBAS equipment that provides precision approach capability and position/velocity/time (PVT) information to navigation management equipment. TSO-C162a, Ground Based Augmentation System Very High Frequency Data Broadcast Equipment, defines an acceptable standard for GPS/GBAS equipment designed to receive a very high frequency data broadcast (VDB) and output the VDB messages to GPS/GBAS positioning and navigation equipment.
b. TSO-C161a and TSO-C162a invoke only the requirements in RTCA/DO-253C, Minimum Operational Performance Standards for GPS Local Area Augmentation System Airborne Equipment, dated December 16, 2008, that are needed to support Category I (CAT I) precision approach and, if applicable, the GPS/GBAS positioning service. The equipment may output PVT based on either the GPS/GBAS positioning service, or PVT from GPS or GPS/SBAS. The PVT based on GPS/GBAS is only available when the ground station supports the positioning service. TSO-C161a equipment must also obtain a TSO-C145d, TSO-C146d, or TSO-C196b TSOA. Requirements in RTCA/DO-253C needed to support precision approaches beyond CAT I are not invoked in these TSOs as these requirements have not been validated.
Once validated, the FAA will either publish TSO revisions or new TSOs.
c. TSO-C161a and TSO-C162a compliant equipment does not address any RNAV capability. A partial missed approach capability is an option in the GPS/GBAS equipment but 14