Primarily for general aviation discussion, but other aviation topics are also welcome.
#1821065
Might this help the OP.
https://www.easa.europa.eu/faq/100695

FAQs
CS-STAN
General Aviation
Clarifications on installation of an ADS-OUT system combined with a transponder system (CS-SC005a) – Configuration 3
Answer
This SC is for the installation of an ADS-B OUT system that is combined with a transponder in a single unit. The Configuration 3 describes the particular case of installation of a transponder that contains an ADS-B OUT system and a GNSS position source that is not approved.

Therefore, the conditions for configuration 3 shall read as:

The ADS-B transmit unit forms part of the Mode S transponder equipment. The transponder equipment and its installation are compliant with CS-SC002c or later amendments, or are otherwise approved.
The GNSS receiver is not approved or its installation is not certified. However, the compatibility of the combination of the transponder and the GNSS receiver is explicitly stated by the manufacturer of the transponder.
The quality indicators are configured according to the manufacturer instructions to report the lowest quality (e.g. SIL = 0 and SDA = 0, NACp = 0). — The installation instructions from the equipment manufacturer have to be followed.
EASA will implement this correction in a revision of CS-STAN issue 3 in the upcoming months, together with other corrections as necessary.
#1821074
EASA will implement this correction in a revision of CS-STAN issue 3 in the upcoming months, together with other corrections as necessary.


My bold. And then, from that EASA page:

EASA wrote:Last updated 18/07/2019

Current Change Information for CS-STAN Issue 3 is here.
#1821076
A large number of this type of transponder are already fitted to flying aircraft. Even today the current Funke advertising describes it as suitable for the basic ADSB out purpose. To have a number of aircraft delegitimised would be a disaster.

SIL 0 is acceptable for the Pilotaware purpose.

Funke needs to keep the promise it made in its own advertising that have clearly influenced the sales of the device. Urgent pressure needs to be focused on Funke. The impact on Funke customer loyalty if they didn’t would be devastating. Funke potentially lead themselves open to legal redress.
#1821082
Another aspect is that it makes a mockery of the whole certification and protected airband system.

We have a device emitting messages on a protected frequency for which it is not certified.

If the authorities do nothing about it, what stops other manufacturer from by-passing certification and just selling products with "certification pending".
Flying_john liked this
#1821132
Interestingly Issue 3 has this

However, the voluntary transmission of additional ADS-B data (e.g. GPS position and velocity) can be
accepted when the position and velocity quality indicators report the lowest quality, the equipment
manufacturer has stated compatibility with the directly connected GNSS source, and the transponder is not
authorised in accordance with ETSO-C166b or equivalent.

But it is withdrawn from Issue 3 of the document - otherwise it may have been something Funke were relying on as a "get out of jail" card.

Without this Para in Issue 3 , as far as I can see, Funke have to comply with C166b - unless there is an "equivalent" alluded to in the deleted paragraph that they are now relying on. If they are it isn't stated in their latest technical spec for the transponder !
#1821141
Funke do not have to comply with ETSO C166b, as long as they don't mark their transponder with it.

1 - Applicability
This ETSO gives the requirements which Extended Squitter Automatic Dependent Surveillance - Broadcast (ADS-B) and Traffic Information Services - Broadcast (TIS-B) Equipment Operating on the Radio Frequency of 1090 Megahertz (MHz) that are manufactured on or after the date of this ETSO must meet in order to be identified with the applicable ETSO marking.
#1821230
patowalker wrote:Funke do not have to comply with ETSO C166b, as long as they don't mark their transponder with it.


And part of that ETS is a technical requirement:-
Minimum Performance Standard
Standards set forth in the RTCA DO-260B, Minimum Operational Performance
Standards for 1090 MHz Extended Squitter Automatic Dependent Surveillance -
Broadcast (ADS-B) and Traffic Information Services - Broadcast (TIS-B), dated
02/12/2009, section 2.

Which they don't comply with either !

Just out of interest, has anyone got a Trig they can look at to see if the unit is marked "Compliant with ETSO C166b"

I know its on the paperwork, but just wondered if they actually marked the unit.

I am trying to think of an analogy to this mess in a non aviation context.
It may be a little like buying a Covid Mask, that has a big hole in it for your nose to come out of !

:roll: :lol: :lol: :lol:
#1821246
Here is an "explanation" that was passed to me. I don't know the date or who in Funke wrote it.

"Starting the development of our transponders many years ago the
ADS-B-stuff required a certified GPS-source. At those times e.g. a
Garmin GNS430 was applicable. The non-certified GPS-stuff was an issue
where the discussions where on the level "allowed or not". Therefore we
developed -what today would be called a basic- NMEA-system giving the
GPS-position to others. This has been the situation during the
certification of our transponders. Keep in mind that other manufacturers
those times just started development, we were already in the market.

The later you come the more you know. As a result newer developments
have been integrating systems doing more than required. Its important to
understand that all this non-certified NMEA-based ADS-B-out is ignored
by true ADS-B-based systems like TCAS. Even the tests of CAA -which have
been done with our technology- do not work with TCAS.

We understand that this seems to be a lack. But keep in mind that this
data is not given by certified GPS and therefore is not reliable. Our
TRTs work with certfied GPS as well and provide all needed
protocols(like Freeflight e.g.).

Until now we do not offer any upgrade to a modified NMEA-ADS-B. We will
check if this could be a developmet for the future."
ronparry liked this
#1821267
Just out of interest, has anyone got a Trig they can look at to see if the unit is marked "Compliant with ETSO C166b"


My Trig TT21's data plate is marked:

ETSO C112c Level 2els, Class 2
ETSO C166a, Class B0
DO-178B Level B
DO-254 Level C
DO-160F
Incomplete System

The TT21TT22 Installation Manual states:

Compliance ETSO 2C112b Class 2 Level 2els, ETSO
C166a Class B0, TSO C112c Class 2 Level
2els, TSO C166b Class B0
#1821274
When you research the TRT800A via their website or under EASA.210.268, it appears to satisfy and comply with all aspects of EU rules.

I find it odd that a unit such as this is deemed unsuitable when it will be operated effectively in a degraded mode in SID/SIL 0 in any case - as are most other similar transponders with ADSB out.

Am I missing something here ? If it has a GPS input from a suitable source, either certified or not, it should provide sufficiently good information for any position awareness system.