AC 20-138C

Historical

Advisory circular · Airworthiness Approval of Positioning and Navigation Systems

A newer version is currentThis is a historical version. AC 20-138D is the version in force, approved March 28, 2014.
Approved
May 8, 2012
Last reviewed
June 12, 2012
Cancels
AC20-138B
Cancelled by
AC20-138D
Family
AC 20-138 · 5 versions
Revision
C
14 CFR parts
21, 23, 25, 27, 29, 43, 91, 97, 121, 135

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 21, 2025.

Show pages 62–73

(3) The vertical guidance presentation should be compatible with the aircraft’s flight instrum entation such that the pilot is continuously furnished the aircraft’s vertical deviation with respect to the pre-programmed ascent/descent or level flight profile.

e. Alert Indications.

Alert indications for the system should be located on or near the vertical path deviation indicator and should provide a readily discernible annunciation to the pilot(s) for any of the following:

(1) Inadequate or invalid navigation signals or sources;

(2) Absence of primary power;

(3) Inadequate or invalid navigation displays or output sources; and

(4) Equipment failures.

Note: These failure/status indications must occur independently of any operator action. Power or navigation equipment failures may be indicated in a common manner.

In the approach mode, the lack of adequate navigation signals or sources will be annunciated by means of a flag displayed on the primary vertical navigation display. In other modes, an appropriately located annunciator may be used.

f. Additional Constraints.

(1) The baro-VNAV equipment should indicate the aircraft vertical path position to the accuracy specified in paragraph 10-2.b within five seconds after any maneuvering or changes in attitude encountered in normal operations.

(2) The system should be capable of providing navigation guidance to the accuracy specified in paragraph 10-2.b within 20 seconds after input of the desired vertical track information (assuming sensor outputs are available).

(3) Navigation guidance should be available within five seconds of waypoint data input.

(4) The equipment should have the capability to meet the criteria outlined in paragraph 10-2 throughout the range of environmental conditions that will be encountered in actual service. Exposing the equipment to the environmental test conditions of TSO-C115b (or later revision) may be used to demonstrate this capability. The environmental test conditions contained in RTCA/DO-160F may be used to demonstrate this ability for baro-VNAV systems certified independent of a multi-sensor RNAV system.

67 Note: Previously certified baro-VNAV systems may have used an earlier RTCA/DO-160 revision. This equipment may still be installed within the provisions of its original certification.

(5) The equipment should provide a means for the flightcrew to determine system status prior to flight.

(6) The equipment should provide the navigation accuracy specified in paragraph

10-2.b for all groundspeeds up to a maximum value, and for all ascent (if applicable) and descent rates up to a maximum value to be set by the applicant.

(7) The equipment should provide a means to alert the flightcrew prior to arrival at a waypoint for anticipating necessary vertical maneuvering. This indicator should be located on or near the vertical path indicator. A procedural means based on a continuous and properly located distance to waypoint display may be used for vertical maneuver anticipation for baro-VNAV equipment that is not coupled to a FD or autopilot.

(a) Systems that provide steering signals for FDs or autopilots should provide automatic vertical maneuver anticipation and a waypoint alert that occurs prior to the initiation of the vertical maneuver. Systems that are coupled to the automatic guidance/control system(s) should not cause the aircraft to depart an assigned altitude until the impending altitude change is indicated to the crew within the pilot’s primary field of view, then acknowledged by timely crew action.

(b) Acceptance of the acknowledgment should not precede the indication if this acknowledgement is stored by the equipment. The acknowledgement timing of an impending vertical path change depends on operational procedures and aircraft/equipment design;

however, past practice has shown that this acknowledgment should not occur more than five minutes prior to the impending vertical path change.

(8) If parallel offset track capability is provided, waypoint alerting and vertical maneuver anticipation should be provided prior to arrival at the point where the offset track intersects the angle bisector of the parent track. These functions should operate as described above in paragraph 10-2.d(7).

(9) The equipment should be capable of providing correct vertical path guidance when interfaced with lateral navigation equipment providing turn anticipation. The baro-VNAV equipment should recognize the angle bisector of the lateral track change as the “zero distance to waypoint” location.

g. The software should be verified and validated to at least level C as defined in RTCA/DO-178B for baro-VNAV equipment that uses a digital computer.

Chapter 11. General Installation Considerations.

11-1. Introduction.

The f ollowing information applies to the installation of all positioning and navigation equipment intended for IFR use.

11-2. Failure Classification.

a. From enroute through Category I precision approach, the loss of navigation function is typically considered to be a major failure condition for the aircraft (see AC

25.1309-1, AC 23.1309-1, AC 27-1, or AC 29-2 as applicable). Other aircraft navigation systems should be considered when determining GNSS loss of navigation, which could be major (no other navigation systems) or minor (other applicable navigation systems).

Navigation data is considered to be misleading when un-annunciated position errors exist. For enroute, terminal, LNAV, and LNAV/VNAV approaches, presenting misleading information to the flight crew is considered to be a major failure condition for the aircraft. For LP/LPV and GNSS Category I approaches, presenting misleading information to the flight crew is considered to be a hazardous failure condition. These failure classifications are summarized in Table 8.

Advisory Vertical Guidance Enroute/ Terminal Area/ Nonprecision Approach (LNAV or RNP

0.3) Nonprecision Approach with Vertical Guidance (LNAV/VNAV) LP/LPV Approach GNSS Precision Approach (Cat. I) Loss of Navigation No Effect Major Major Major Major Misleading Information Minor Major Major Hazardous Hazardous Table 8. Typical Hazard Classifications

Note: For RNP values less than 0.3, losing RNP capability constitutes loss of navigation. Refer to appendix 2 for further RNP AR airworthiness information and AC 90-101 (latest revision) for complete guidance on RNP AR operations.

b. The applicant must conduct a safety assessment of the positioning/navigation equipment installation to verify that design errors and failure modes meet the probability requirements for that failure class. AC 23.1309-1, AC 25.1309-1, AC 27-1, or AC 29-2, per the latest revision levels, provide an acceptable means for showing that the hardware complies with pertinent airworthiness requirements. See paragraph 14-2.a for GPS/SBAS and GPS/GBAS retrofit installation guidance related to navigation displays previously approved for ILS.

c. Any probable failure of the positioning/navigation equipment must not degrade or adversely affect the normal operation and performance of other required equipment or create a 68

flight hazard . The interfaces with other aircraft equipment must be designed such that normal or abnormal positioning/navigation equipment operation must not adversely affect the operation of other equipment nor must operation of other equipment adversely affect the positioning/navigation equipment operation.

11-3. Software Considerations.

a. AC 20-115B Radio Technical Commission for Aeronautics, Inc. Document RTCA/DO-1 78B, defines an acceptable means of qualifying software. In December 2011, RTCA published RTCA/DO-178C, Software Considerations in Airborne Systems and Equipment Certification. The FAA plans to update AC 20-115B to recognize RTCA/DO-178C as an acceptable means of qualifying software, but there currently is no AC or TSO recognition for RTCA/DO-178C. In the interim, applicants may choose to use RTCA/DO-178C instead of RTCA/DO-178B provided they declare their intention to the applicable aircraft certification office for the project. However, doing so will most likely require submitting a deviation request, particularly if a TSO that invokes RTCA/DO-178B is involved.

b. The applicant is encouraged to submit the Plan for Software Aspects of Certification (PSAC) early in the software development process. Early submittal will allow timely resolution of issues such as partitioning and determining software levels. Software certification is normally addressed during the design approval for positioning/navigation equipment, but should be confirmed at installation to ensure the certification level is appropriate for the installation intended function.

Note: It may be possible to obtain approval for navigation functions that have hazardous level effects with FMS software developed to DO-178B level C criteria. AC 20- 174, Development of Civil Aircraft and Systems provides an acceptable method for establishing design assurance levels.

This guidance may be helpful for navigation architectures containing independent functions.

11-4. Hardware Considerations.

AC 20-152 (latest revision) RTCA, Inc., Document RTCA/DO- 254, Design Assurance Guidance for Airborne Electronic Hardware, defines an acceptable means of qualifying complex electronic hardware devices. The applicant is encouraged to submit the Plan for Hardware Aspects of Certification (PHAC) early in the development process. Hardware certification is normally addressed during the design approval for positioning/navigation equipment; but, should be confirmed at installation to ensure the certification level is appropriate for the installation intended function.

11-5. Installed Equipment Compatibility.

There is no one, single, standard ized interface for positioning and navigation equipment to other equipment on-board the aircraft such as displays, autopilots, terrain warning, etc.

Positioning and navigation equipment manufacturer’s installation manuals/instructions should define what other equipment is compatible with the positioning and navigation system.

Equipm ent manufacturers are encouraged to develop compatible equipment lists and/or detailed interface requirements for their installation manuals/instructions. The installer must ensure that other on-board equipment interfaced with the positioning and navigation systems is compatible, and the airworthiness approval holder is ultimately responsible for defining the installation. But the installation burden is greatly eased when equipment manufacturers define compatible systems in their installation manual/instructions, including software version and/or part number if necessary.

11-6. Installation Instructions.

a. The equipment m ust be installed in accordance with the instructions and limitations provided by the positioning and navigation equipment manufacturer. The airworthiness approval will address any additional installation specifics.

b. Equipment should be installed with separation between wires of redundant equipment (see AC 43.13-1 latest revision). Wire separation will mitigate the possibility of loss of navigation due to a single event. During installation approval of the system, when wire separation cannot be achieved, the following questions must be evaluated and the potential for single event upsets minimized:

(1) Is it possible for a cable harness to be exposed to wire chafing in a manner that both channels fail simultaneously?

(2) Is the cable harness located near flight control cables, high electrical capacity lines or fuel lines?

(3) Is the cable harness located in a protected area of the aircraft (isolated from engine rotor burst)?

(4) Is any electromagnetic interference (EMI) between systems caused by cable routing?

11-7. Environmental Considerations.

a. Most equip ment will have been tested by the equipment manufacturer to the environmental categories described in RTCA/DO-160 (applicable revision), with results described in an environmental qualification form. The airworthiness approval applicant must ensure the environmental categories (or criteria) to which the equipment has been tested are compatible with the aircraft environment in which the positioning and navigation equipment is installed. See AC 21-16F (or later revision) RTCA Document DO-160 versions D, E, and F, Environmental Conditions and Test Procedures for Airborne Equipment, for guidance on differences among RTCA/DO-160 versions D, E, and F.

b. For equipment that has not been tested to the environmental categories described in RTCA/DO-160 (applicable revision), either the equipment manufacturer or airworthiness applicant must thoroughly define the intended aircraft environment and conduct comparable normal and abnormal environment testing.

11-8. General Human Factors Considerations.

a. Control Accessibility.

(1) Controls installed for in-flight operation should be readily accessible from the flight crew’s seated position. Only single-hand operation should be required, the controls should be readily identifiable, and the use of controls should not obscure pertinent displays.

(2) The equipment should be designed so that controls intended for use during flight cannot be operated in any position, com bination, or sequence that would result in a condition detrimental to the operation of the aircraft or the reliability of the equipment.

(3) Controls should provide feedback (e.g., tactile, visual) when operated.

(4) Control operating force should be appropriate for its intended function.

Note: Low forces might provide insufficient feedback, while high forces might impede intentional rapid use.

(5) Controls should be resistant to inadvertent activation. Common and acceptable means of reducing the likelihood of inadvertent operation through design include the following:

(a) Placing fences between closely spaced adjacent controls.

(b) Concave upper surface of keys to reduce slippage.

(c) Size of control surface sufficient to provide for accurate selection.

(d) Placing guards over controls.

(e) Providing appropriate sensory feedback, or explicit confirmation of activation.

(6) The function for each control should be indicated, unless obvious. Pilots should be able to quickly and accurately determine the function of the control with minimal experience or training. If a control can be used for multiple functions, the current and inactive functions should be distinguishable.

(7) Controls/input devices should be organized according to the following principles, when feasible:

(a) Controls should be organized in logical groups according to function and frequency of use.

(b) Controls should be easily associated with the related elements (e.g., displays and labels) that identify their function. For example, line select function keys should align with adjacent text.

(c) Controls used m ost frequently should be the most accessible.

(d) Dedicated controls should be used for frequently used functions.

(e) Line select function keys should align with adjacent text.

(8) Use of two or more controls simultaneously (e.g., pushing two buttons at once) in flight should not be required to perform a function.

(9) Controls that do not require adjustment by the flight crew (e.g., maintenance functions) should not be readily accessible to the flight crew.

(10) Controls and their labels should be identifiable during all normally expected ambient light conditions, including direct sunlight and nighttime.

(11) Control identifiers and other information should not be obstructed by the control input devices.

b. Display Visibility.

(1) Each display element, used as a primary flight instrument in the guidance and control of the aircraft, should be located where it is clearly visible to the pilot with the least practicable deviation from the pilot’s normal position and line of vision when looking forward along the flight path.

Note 1: CDI displays contained in the Control Display Unit (CDU) will most likely not be acceptable for IFR operations.

Note 2: FTE can be reduced when numeric display information is integrated with the non-numeric display or is located within the pilot’s primary field of view. Both digital cross-track and track angle error have been shown to reduce FTE. This information should be displayed together (either within the CDU or remotely displayed near the non-numeric display) for better tracking performance.

Using non-numeric cross track data integrated with nonnumeric track angle error data into one display may provide the optimum situation and control information for the best overall tracking performance.

(2) The appropriate flight crew member(s) should have an unobstructed view of displayed data when in the seated position.

(3) Connection to external displays (CDI, horizontal situation indicator (HSI), moving map, annunciator panel, etc.) should be consistent with the equipment installation instructions.

(4) The horizontal (and vertical) deviation(s), display(s), and failure annunciations should be located within the pilot's primary field of view, as should any indication requiring immediate aircrew action.

(5) Compliance with limitations in the equipment installation instructions for display readability should be verified.

c. Lighting Conditions.

(1) All displays, controls, and annunciators must be easily readable under all normal cockpit conditions and expected ambient light conditions (total darkness to bright, reflected sunlight).

(2) Night lighting provisions must be compatible with other cockpit lighting, particularly if night vision goggle compatibility is desired.

11-9. Magnetic Variation Data and Onboard Database.

a. Avionics typically convert true heading references to m agnetic heading references by using worldwide magnetic variation data contained in an on-board magnetic variation database and a set of software algorithms. The algorithms convert the data into a specific magnetic heading reference for a specific geographic reference point. However, since the Earth’s magnetic fields constantly change, magnetic variation databases need periodic updates to provide accurate magnetic heading references. The National Oceanic and Atmospheric Administration (NOAA) offers a World Magnetic Model available at http://www.ngdc.noaa.gov/geomag/geomag.shtml, and this product is an acceptable source for updating an aircraft magnetic variation database. NOAA updates the model on a five-year cycle, and magnetic variation databases should be updated consistent with this cycle.

Note: If the magnetic variation database is not kept current, the navigation systems no longer support their intended functions for use during flights conducted under IFR. Failure to maintain and update the magnetic variation database can result in presentation of misleading magnetic heading references that can result in placing the aircraft outside the terrain and obstacle protection provided in instrument procedure and route designs.

b. Equipment design approval holders should identify any operating limitations in their equipment associated with application of the magnetic variation data (e.g., operations using magnetic heading references may only be valid between 82° north latitude and 82° south latitude) to ensure accurate magnetic heading references are presented and used in the aircraft.

The equipment design approval holders should also define a continuing airworthiness requirement to update the magnetic variation database and, if applicable, conversion algorithms or hardware when the periodic updates become available. This requirement should also define the maintenance procedures necessary to update the on-board magnetic variation database for their avionics.

Chapter 12. General In stallation Considerations - Antennas.

12-1. Antenna placement.

Paragraphs (a) through (f) below are specific to GNSS antennas.

a. Typically, a GNSS antenna is lo cated forward or aft of the wings on the top of the fuselage.

b. GNSS antennas must be installed to provide the widest, unobstructed field of view to the satellites. The antenna installation instructions should provide information on how to determine a location that minimizes the potential for signal blockage by any portion of the aircraft. Shadowing by aircraft structure (and in some cases by rotorcraft blades) can adversely affect the operation of the GNSS equipment.

c. The antenna placement on the airframe should be optimized to ensure the receiver can take full advantage of a 5 degree mask angle (or lower if the receiver installation instructions identify the equipment is certified to a lower mask angle). This includes consideration of antenna location with respect to blockage from airframe components, airframe structures, engine components, or other antennas with the aircraft at typical level cruising attitude. The antenna should also be located to minimize the effects of aircraft shadowing during typical maneuvers.

d. The antenna should be separated as much as practical from transmitting antennas

(e.g., VHF and high frequency radio, satellite communications (SATCOM), DME, direction finder, emergency locator transmitter, and traffic and collision alerting system). For small aircraft, the antenna should also be separated as much as practical from the windscreen to prevent case-to-antenna coupling.

e. The VDB antenna should be installed so that the maximum received power from any on-board transmitter does not exceed the desensitization levels of the VDB receiver specified in RTCA/DO-253C, paragraph 2.2.9.1.

f. The GNSS multi-path error model specified in RTCA/DO-229D and RTCA/DO-253C was developed and validated using flight test data collected on a variety of large, fixed-wing aircraft. Further validation was done using computer modeling of large, fixed-wing aircraft. For installations on rotorcraft, antenna location should consider the compatibility of the resulting multi-path errors with this model. This may require additional equipment functional flight evaluation or analytical evaluation to confirm the antenna location is suitable.

g. For installations on rotorcraft, the effects of the rotor blades on antenna performance should be considered. This may require additional equipment functional flight evaluation or analytical evaluation to confirm the antenna location is suitable.

h. For multiple-sensor installations, the installer should reduce the likelihood that a single lightning strike affects all the sensors (i.e., do not place them in a straight line from the front to the rear of the fuselage).

12-2. Anti-Ice Protection.

If the aircraf t is approved for flight into known icing conditions, the antenna must not be susceptible to ice buildup (i.e., is installed in a non-icing location on the aircraft, or is of a sufficiently low profile that ice does not accumulate on the antenna). Alternatively, the equipment can be shown to operate satisfactorily when the antenna is subject to icing if there are no harmful effects of the ice build-up, such as possibly ingesting accumulated ice into the engine or degradation in aerodynamic performance. The effects of ice accumulation on the antenna, if any, can be found in the equipment manufacturer's installation manual/instructions.

See the latest revisions of ACs 23.1419-2 and AC 25.1419-1 for additional fixed-wing aircraft guidance. For additional rotorcraft guidance, AC 27.1419 is contained in the latest revision of AC 27-1 and AC 29.1419 is contained in the latest revision of AC 29-2.

12-3. Antenna Cables.

Double shielded cables should be used to prevent interference coupling into the cable.

12-4. Structure.

Any m odifications to the aircraft to install a new antenna need to be evaluated as part of the airworthiness approval for their impact on aircraft structure. Examples are evaluating and testing antenna installations for buffet and vibration (compliance with 14 CFR part XX.251), or when modifying pressurized structures (compliance with 14 CFR part XX.841 and XX.843).

For specific guidance relating to modifications in the fuselage structure, see AC 43.13-2 (latest revision). Additional guidance information related to structures can be found in the latest revisions of ACs 20-107, 23-13, and 25.1529-1.

Chapter 13. General In stallation Considerations - Sensors.

13-1. Introduction.

This chapter provides guidance related to positioning/navigation sensor installation. T his chapter also applies to stand-alone navigation equipment installation, since that equipment has an embedded sensor. This guidance applies to all installations, but is only expected to be specifically evaluated as part of the initial airworthiness approval (i.e., initial airworthiness approval may provide sufficient substantiation for follow-on installations).

13-2. Positioning and Navigation Configuration Strapping.

Often, positioning and navigation equipm ent uses software configuration straps or installation set parameters entered either manually by the installer or by using an aircraft personality module. These software configuration straps or parameters disable/enable functionality; configure the input/output formats; determine the displayed units of measure; etc.

The software configuration programming documentation must become a part of the installation package and should be included in the master drawing list. When using an STC-AML (see paragraph 2-3), approved multiple configurations may be specified.

13-3. Navigation Source Selection.

a. For insta llations where positioning and navigation outputs can drive a display that is shared with other navigation equipment (e.g., VOR/DME, ILS, GPS/SBAS, baro-VNAV), the pilot must be able to select the source of guidance, and the selected source must be clearly annunciated to the flightcrew on or near the affected display.

b. There are many possible navigation source and service level combinations and permutations given the variety of sensors and capabilities that can be integrated into the aircraft.

Some of the capabilities are very similar, but have subtle differences that are very significant.

The aircrew must have a clear, unambiguous annunciation of what capability is being provided by the navigation system. This can either be accomplished by multiple annunciation indicators, or by removing some navigation capabilities when others are added to reduce the annunciator complexity.

c. GNSS-based navigation (GPS, GPS/SBAS, GPS/GBAS) might not require differentiation unless integration complexity requires it for clear, unambiguous indication of selected capability to the flightcrew. For example, oceanic, enroute, or terminal RNAV modes or LNAV-only approach capability may not require differentiation.

d. When applicable, annunciation of the selected source should be driven by the same relay switch to preclude erroneous information in case of switch failure.

e. Autopilot navigation modes related to the navigation source should be inhibited if the displayed source is not the same as the source driving the autopilot. This is particularly critical for approach operations (i.e., autopilot in approach mode). One possible method is to consider integrations that do not permit separate display source and autopilot source navigation 76

selection.

f. Navigation source annunciations included in the optim um primary field of view do not also have to be shown on a heads-up display.

13-4. Dual Positioning and Navigation Installation s.

a. Paragraph 13-4 describes guidelines for synchronizing dual positioning and navigation equipment installations. Synchronization refers to the ability for control inputs to one positioning and navigation equipment set to automatically update the other equipment set.

Dual installations should be synchronized whenever possible to reduce crew workload and prevent confusion over which system/flight plan is driving the navigation data. If the functional hazard assessment requires dual positioning and navigation equipment or is operationally required, then synchronization is required.

b. If the navigation equipment is not synchronized, then the following issues should be evaluated:

(1) The pilot and co-pilot (if applicable) should be able to view and enter data in the offside equipment. This must not interfere with throttle levers, flap handle, etc.

(2) The workload associated with manually updating both equipment sets to maintain consistency between them should not be too burdensome.

(3) There should be no possible confusion as to which equipment is driving the autopilot and navigation displays.

(4) Controls, displays and annunciations must not result in misleading information, pilot confusion or unacceptable workload due to possible inconsistencies from differences in the equipment (e.g., different flight plans making one unit go into approach mode while the other does not). Evaluations for these types of inconsistencies are of particular concern when the cockpit architecture enables cross coupling (e.g., GNSS-2 switched to drive side 1 displays).

13-5. Intermixing RNAV equipment.

a. Where m ultiple RNAV systems are intended to be used simultaneously (typically in two-pilot aircraft), installing area navigation equipment with different crew interfaces can be very confusing and could lead to problems since they may have conflicting methods of operation and conflicting display formats. There can be problems even when intermixing different versions of the same equipment.

b. At a minimum, consideration should be given to the following potential incompatibilities, particularly when the cockpit architecture allows for cross coupling (e.g., RNAV-2 switched to drive side 1 displays):