TAA - Garmin G5

First, how does the FAA define TAA?
 

§ 61.129(j) defines TAA as:

Unless otherwise authorized by the Administrator, a technically advanced airplane must be equipped with an electronically advanced avionics system that includes the following installed components:

(1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;

(2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving map using Global Positioning System (GPS) navigation with the aircraft position displayed;

(3) A two axis autopilot integrated with the navigation and heading guidance system; and

(4) The display elements described in paragraphs (j)(1) and (2) of this section must be continuously visible.

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In the Pilot's Handbook of Aeronautical Knowledge (PHAK) glossary the FAA defines PFD as:

Primary flight display (PFD). A display that provides increased situational awareness to the pilot by replacing the traditional six instruments used for instrument flight with an easy-to-scan display that provides the horizon, airspeed, altitude, vertical speed, trend, trim, and rate of turn among other key relevant indications.

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And also in the PHAK glossary the FAA defines MFD as:

Multi-function display (MFD). Small screen (CRT or LCD) in an aircraft that can be used to display information to the pilot in numerous configurable ways. Often an MFD will be used in concert with a primary flight display.

 

So let's look at an installation with two Garmin G5s.  Does such an installation meet the requirements of 61.129(j)(1) - "includes, at a minimum, an airspeed indicator, turn coordinator, altitude indicator, heading indicator, altimeter, and vertical speed indicator"?  Indeed it does.  (Note that a single G5 installation provides all of those functions but doesn't meet the requirement in 61.129(j)(4) - "must be continuously visible".  It requires two G5s to meet this requirement.

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Does a GPS navigation device like the Garmin GTN650 meet the requirements of an MFD as spelled out in 61.129(j)(2) - "a moving map using Global Positioning System navigation with the aircraft portion displayed"? Obviously it does.

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Include an autopilot that controls the aircraft in at least roll and pitch, which can be coupled to the heading/VOR signal from the PFD or the GPS signal from the MFD and you've met the requirements.  By the way, the FAA specifically states that the autopilot doesn't need to have GPSS input.

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Arguments I've heard as to why this configuration doesn't meet the FAA requirements for TAA include:

1) The autopilot annunciator display must be on the MFD.  

Here's what the FAA says specifically about having autopilot functions displayed outside of the MFD:

The TAA requirements in no way restrict the use of peripheral or supporting equipment that enables the display functionality described for the PFD and MFD in the TAA requirements…​

While there may be different TSOs for the various functions of GPS, moving map, and navigation resulting in separate pieces of underlying equipment, this equipment can support the MFD requirements so long as the MFD includes a moving map that uses GPS navigation with the aircraft position displayed…

It's clear that no such requirement for autopilot function display exists in the definition of TAA.

2) The Garmin G5 is not a "primary instrument" so it can't be used as a PFD as defined by the FAA.  

The distinction here is between the name of the unit (Primary Flight Display) and its certification as a primary instrument.  The FAA doesn't address the need for the PFD to be primary, only that it needs to contain the featured found in 61.129(j)(1).  I haven't seen any FAA documentation that states that the PFD must be primary.

3) A moving map like the Garmin 430/530 or the GTN650/750 doesn't qualify as an MFD because you can change the display page away from the moving map, and the regs state that the map "must be continuously visible."  

I've never flown behind an MFD that couldn't be paged between the map and other functions, that's what make it "multi-".  It's obvious to me that the FAA's intention was to exclude avionics where the pilot had to page between the PFD functions and the moving map.

 

If you have questions about a specific avionics setup in an airplane you're using to meet the TAA requirements for the commercial certificate, don't hesitate to reach out. ​