Aviation Communication & Surveillance Systems (ACSS)

Document ID: FAA-2010-1204-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: January 07 2011, at 12:00 AM Eastern Standard Time
Date Posted: January 13 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: December 28 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: February 11 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80bc6f7e
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This is comment on Rule

Airworthiness Directives: Various Aviation Communication and Surveillance Systems Traffic Alert and Collision Avoidance System Units

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Regarding the statement under “FAA’s Determination and Requirements of This Proposed AD” of “We are proposing this AD because we evaluated all relevant information and determined the unsafe condition described previously is likely to exist or develop in other products of these same type designs” ACSS feels it relevant to clarify that the operation of the Interference Limiting (IL) function that is in question was not the result of an error in implementation. The IL function was specifically implemented to operate as it does in order to comply with the requirements of the TSO Minimum Operational Performance Standards (MOPS) for Change 7 (i.e., TSO-C119b) as interpreted by ACSS. As such, the statement “…likely to exist or develop in other products of these same type designs” is misleading in that ACSS has already implemented the FAA directed change in all current and future versions (e.g., TSO-C119c; Change 7.1 compliant systems). ACSS would recommend that the wording be changed to: ”…exists in various ACSS TCAS systems.”