Approval / certification process for avionics manufacturer

[SDB73]

Hi All,

This is a very preliminary / idle thought right now, but I have an excellent electronics r&d team, and would like to investigate the barriers to entry into the avionics market.

We have the capabilities to design and build pretty advanced avionics, but I know nothing about the approvals / certification requirements, and would appreciate some pointers / bullet points I can then do some further research on.

[goldeneaglepilot]

Hi,

A very difficult task to do, the R&D is the easy part - the certification is a nightmare with regards aviation (unless its a homebuilt, in which case it becomes much easier for certain things).

[Genghis the Engineer]

I tend to agree with GoldenEaglePilot - start in the uncertified (permit / homebuilt / microlight / experimental) market first of all to learn most of the lessons about the market and operating environment. Once established, start exploring whether there's a market in the certified world for any of your products, and at that point start thinking about what approvals you need for that specific equipment.

This is the route that has been taken by most of the newer companies in GA:whether it's avionics, engines, propellers, or whole aeroplanes over the last 30odd years, and it works.

G

[Pilot DAR]

SDB73,

I cannot speak to the process in the UK. However, I have started and had approved several Transport Canada approved manufacturers - though not for avionics. I would expect that like Canada, in the UK, it's probably something like: When you know that you have what it takes to do it, and can demonstrate it, you probably can be approved to do it.

I don't say this to be exclusive, it's more like the old saying, if you have to ask "how much?", you probably cannot afford it. I know that generally, the regulators, despite their desire to assist, don't have the time or mandate to lead applicants through the process. You have to present an application and proposal which is pretty well compliant going in the door.

Consider that (using the Canadian model) you have regulatory approval of both the new design (probably by TSO or STC), and the company itself who will produce and certify it. These are two very distinct activities, and probably must happen concurrently for the first product.

Some of the standards which might prevail over avionics will be found here:

Index to RTCA Documents (http://www.rtca.org/downloads/List%20of%20Available%20Docs%20-%20Sept%202011.htm)

Others will be found in the "Part.23" series of the FAA FARs, or your national equivalent (assuming that you're talking light fixed wing aircraft). Available here:

RGL Home (http://rgl.faa.gov/)

The Canadian standards for approving an aviation manufacturer (irrespective of product type) are here, just for your reference:

(read this, and the associated standard linked at the top) Part V - Airworthiness - Transport Canada (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-subpart61-238.htm)

[IO540]

I've looked into a few avionics possibilities too.

Certication is not the biggest problem. The existing players always pretend it is, to justify their silly pricing. For example the manufacturing cost of a GNS430 is about $300.

The biggest barrier to entry in GA avionics is the distribution/installation pipeline. The installers are very loyal to the existing principals who give them nice trade discounts and provide then with good tech support. Most avionics installers (UK and USA and elsewhere) are basically just wiremen, and while a lot of avionics installs can be done almost wholly just by reference to the wiring diagrams in the back of the Installation Manuals, many can't, and a lot of planes have weird wiring and other existing issues which one has to work with.

And one cannot bypass the resellers because the installations cannot be legally done by aircraft owners.

Obviously some things will be easier to certify than others. If you wanted to knock up a new autopilot (computer, and servos) you will have a big job, but you will have a bigger job producing the STCs for enough aircraft types to create a big enough market. There is a lot of testing involved (and not all GA AP makers have done it ;) ). But something simple and standalone like a panel mounted CO detector would be a lot easier.

There are more openings in the non-CofA market, because you don't need to sell via installers, but that market is well covered in most respects. Look at the US homebuilt avionics market for example.

The obvious market to go for is portable stuff. That needs no approvals and can be sold mail order direct to aircraft owners. You just need to find something people want to buy :)

[Zulu Alpha]

And one cannot bypass the resellers because the installations cannot be legally done by aircraft owners

..unless its an LAA homebuilt where owners can do these things.

[IO540]

That's what I said

There are more openings in the non-CofA market, because you don't need to sell via installers

[JOE-FBS]

Your location is given as the UK so your regulator is EASA.

EASA has three relevant regulatory systems.

ETSO (European Technical Standards Orders) are equipment approvals. Gaining the relevant ETSO for a piece of equipment shows that it meets certain Minimum Performance Standards and makes the subsequent task of putting that equipment approved onto a flying machine slightly easier. To be able to apply for ETSO, you need to have an Alternative Design Organisation Approval. All the ETSO requirements are listed here:

http://easa.europa.eu/agency-measures/docs/certification-specifications/CS-ETSO/CS-ETSO.pdf

Looking at the contents list for this, you will be able to find the relevant ones for your business. When applying for an ADOA, you specify for which ETSO you want to be able to apply. Note that I have directed you to the initial issue of CS-ETSO. It has been amended several times but EASA has not issued a consolidated update. One has to plough through the amendments here:

EASA - Certification Specifications (http://easa.europa.eu/agency-measures/certification-specifications.php#CS-ETSO)

The requirements for ADOA are here:

EASA - Alternative Procedures to Design Organisation Approval (ADOA) (http://easa.europa.eu/approvals-and-standardisation/organisation-approvals/alternative-procedures-to-design-organisation-approval-ADOA.php)

To approve a piece of equipment onto a flying machine (assuming you do not get it fitted by the OEM as part of the type certificate which is unlikely for you at this stage), requires either a Minor Modification or a Supplementary Type Certificate (a major modification). Minor mod's and STC can be issued or applied for respectively by organisations holding relevant Design Organisation Approvals. The technical rules for flying machine certification are contained in Certification Specifications. There are different ones for different classes of flying machine, see here:

EASA - Certification Specifications (http://easa.europa.eu/agency-measures/certification-specifications.php)

If you don't want to go through the above, you can partner with an established design organisation. There are several dozen in the UK. I work for such a one called Tenencia. There are full lists here:

http://easa.europa.eu/approvals-and-standardisation/organisation-approvals/docs/lists/easa_doa.pdf

and here

http://easa.europa.eu/approvals-and-standardisation/organisation-approvals/docs/lists/easa_adoa.pdf

It all takes time and money but is not the impossibility the nay sayers will have you believe. I have been in the EASA certification game since 2004. No, I'm not touting for a job from you! Well not yet anyway :-)

[IO540]

It may be easier to go for an FAA STC and then you have a 10x bigger market anyway.

Very useful post joe-fbs :ok:

[SDB73]

IO540,
Valid point re US STC = 10 x the market place.

Joe,
Awesome information, thank you!

Pilot DAR,
Thank you also.

Genghis and GoldenEaglePilot,
Thanks guys. I know it's going to be tough, but just want to assess exactly how tough.

Thanks again for taking the time to reply.

[Rod1]

If you are interested in the permit side of things then Transponders and Radios need certification, just about anything else does not, including autopilots. If you have a look at Partsforaircraft you will get some idea of the range of products available. Distribution is just a matter of getting a similar organization to sell your stuff and give a selection to the LAA for use in its avionic courses. You then have to duplicate for each area.

As a general rule an EFIS will be at least an order of magnitude cheaper than a certified unit with less functionality. Durability in my experience is very good. In the US there are a number of TSOed Mode S transponders for the equivalent of £750 ish but the manufacturers have given up on getting EASA approval.

Rod1

[IO540]

I agree the "homebuilt" market is worth a serious look, but at the same time one has to come up with something novel.

No good producing yet another "obvious product" which is an EFIS unit, which is basically an embedded "IBM PC", interfaced to an off the shelf AHRS module, a GPS and some airdata sources, with some software knocked up to generate the graphics. Pop over to the Friedrichshafen show next April and see that every man and his dog are exhibiting one of these already. It takes about 6 man-months to knock up the software, if you are clever. A lot of them are pretty naff implementations, however.

I think one could make a box like a G695, but more open (so one could load own georeferenced maps, load up Memory Map QCT maps, load up Oziexplorer maps, and PDFs of approach plates), and sell it for far less than Garmin are charging for theirs. One could sell that by mail order. The main challenge is where to get the map data from....

Best to look for a very simple standalone gadget. I can't think of one off hand but an example would be a panel mounted CO detector.

Actually there is one thing you could do: an electronic oxygen demand regulator (http://www.peter2000.co.uk/aviation/oxygen2/index.html), like the MH O2D2 but
a) cheaper
b) fail-safe (battery flat -> max flow; the MH unit fails shut ;) )
c) externally powered with auto fallover to internal battery
d) 4 outputs
Being portable, you could sell it mail order.
Check for patents though. In the USA you can patent almost anything, regardless of obvious prior art.

10% please ;)

[stickandrudderman]

I think the OP, if he has the resources and capability, is on to something.
I've just installed "full glass" in my Falco and I had an absolute nightmare trying to find not just the right equipment at an affordable price, but the right supplier.
I ended buying direct from AFS in the US, not just because I thought their product was excellent, but because their comms and public resources gave me confidence.
There are still some shortcomings as a result of them being focused on the US market though and it would be great to have a European company producing something of similar quality and with similar approach. Too late for me now but I'm sure there are plenty of LAA owners who are either building or thinking of upgrading who are having similar issues.
Whether the market is big enough to warrant the trouble is another matter.

[jxk]

Would it be possible to make a 'GPS' type of device that didn't rely on satellite technology? I understand it's very easy to 'jam' a GPS signal with just a 1 watt transmitter.

[IO540]

You can get inertial navigation starting at £25k. I posted the details here a few weeks ago. It's an off the shelf box, with fibre optic gyros. You still need a GPS fix initially, of course.