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May 3rd 06, 05:23 AM
I've seen other discussions get off topic and go on about handheld GPS
use under IFR. And people get all worked up about it. I know there is
a lot of history on this newsgroup, but I haven't followed most of it
(so don't lynch me, please).

It seems that a lot of pilots believe a handheld GPS shouldn't be used
while IFR. And a lot more believe that it can't be the "primary"
navigation method. Sometimes that makes sense, but other times it
doesn't (to me). So here are a few questions I have that work up to
GPS:

1) Can you use celestial navigation while IFR? And does your sextant
have to be "approved" in some way?

2) Can you use dead reckoning for IFR navigation? If so, can you use
your wrist watch as your "primary" timer? Or does it have to be an
"installed" clock? And to do dead reckoning calculations, can you use
a drugstore-bought calculator? An abacus? Or how about a handy "dead
reckoning computer" that calculates ground speed and track?

I can understand that a handheld GPS is not supposed to be used as a
substitute for VOR or DME or ADF (say for navigating along airways or
for shooting instrument approaches). But can you not use one for
flying off-airway routes without playing tricks (like pretending to
double-check position with VOR/DME or asking ATC for a vector and then
ignoring the heading they issue)?

A Lieberman
May 3rd 06, 05:46 AM
On 2 May 2006 21:23:33 -0700, wrote:

> asking ATC for a vector and then
> ignoring the heading they issue)?

If it looks like a troll, walks like a troll, quacks like a troll, it must
be a troll.

Allen

May 3rd 06, 05:59 AM
>> asking ATC for a vector and then
>> ignoring the heading they issue)?
>
> If it looks like a troll, walks like a troll, quacks like a troll, it must
> be a troll.

Thanks. Maybe speling and grammar like a troll, but walking and
quacking?

I'm serious, though. I have heard several pilots tell ATC that they
have a handheld GPS and then ask for a vector. What's the point? If
you're going to ask for a vector why add the bit about the GPS? I can
only assume that they intend on flying the course from the handheld,
but ask for a vector because they've heard that its "legal" if you do
it that way.

On the other hand, I've had a controller ask me if I had a handheld
because he wanted me to fly direct to a VOR well outside reception
range. I didn't have one with me on that flight, so instead he gave me
a vector (it was a slow night).

Peter

Paul Tomblin
May 3rd 06, 02:29 PM
In a previous article, said:
>I'm serious, though. I have heard several pilots tell ATC that they
>have a handheld GPS and then ask for a vector. What's the point? If
>you're going to ask for a vector why add the bit about the GPS? I can
>only assume that they intend on flying the course from the handheld,
>but ask for a vector because they've heard that its "legal" if you do
>it that way.
>
>On the other hand, I've had a controller ask me if I had a handheld
>because he wanted me to fly direct to a VOR well outside reception
>range. I didn't have one with me on that flight, so instead he gave me
>a vector (it was a slow night).

On Saturday, I got an IFR clearance "KROC direct GEE direct KAGC", which
as soon as I got airborne was ammened to "direct KAGC". I was /A and I'd
filed along airways, but they must have known I had a handheld on board
and it was CAVU because I couldn't have flown that in IMC with the
equipment installed on the plane.


--
Paul Tomblin > http://xcski.com/blogs/pt/
IMAP is just not a very rich protocol.
-- Steve Conn, Exchange Server product manager for Microsoft

Tim Auckland
May 3rd 06, 05:33 PM
Here's my layman's understanding of this. I hope someone will jump
in and correct me if I've got something wrong,

If you're IFR en-route, ATC has three ways of directing you::

a) via an airway;
b) direct;
c) vectors;

ATC needs to have you on radar to issue (b) or (c).

You should only accept a direct clearance if you're confident you can
navigate direct.
It doesn't matter what method you plan to use to navigate direct -- it
can be dead reckoning, celestial navigation, visual (if you're VMC),
VOR, hand-held GPS, panel-mount GPS, etc.

If you're not confident you can navigate direct, then you should
refuse the direct clearance. ATC already has you on radar, so it's
typically no big deal for them to issue a radar vector instead.

What happens if you've accepted a direct clearance, and your hand-held
GPS's battereis die?
It's just the same as any other reason for being unable to navigate
direct (clouds cover the stars, you can no longer see your
destination, your ham sandwich falls to the floor...). You inform
ATC, eg:
"Cessna 12345 is no longer able to navigate direct xyz. Request
radar vectors."
(Remember, they've already got you on radar to issue the direct
clearance.)

So, it's OK to accept a direct clearance, even if you're /U, as long
as you're confident you can do the navigation.

It's also good practice to always cross-check your navigation using
some independent means.

Once again, if any of this is wrong, stupid, or illegal, please
correct me. I'm here to learn!

Cheers,

Tim.


On 2 May 2006 21:23:33 -0700, wrote:

>I've seen other discussions get off topic and go on about handheld GPS
>use under IFR. And people get all worked up about it. I know there is
>a lot of history on this newsgroup, but I haven't followed most of it
>(so don't lynch me, please).
>
>It seems that a lot of pilots believe a handheld GPS shouldn't be used
>while IFR. And a lot more believe that it can't be the "primary"
>navigation method. Sometimes that makes sense, but other times it
>doesn't (to me). So here are a few questions I have that work up to
>GPS:
>
>1) Can you use celestial navigation while IFR? And does your sextant
>have to be "approved" in some way?
>
>2) Can you use dead reckoning for IFR navigation? If so, can you use
>your wrist watch as your "primary" timer? Or does it have to be an
>"installed" clock? And to do dead reckoning calculations, can you use
>a drugstore-bought calculator? An abacus? Or how about a handy "dead
>reckoning computer" that calculates ground speed and track?
>
>I can understand that a handheld GPS is not supposed to be used as a
>substitute for VOR or DME or ADF (say for navigating along airways or
>for shooting instrument approaches). But can you not use one for
>flying off-airway routes without playing tricks (like pretending to
>double-check position with VOR/DME or asking ATC for a vector and then
>ignoring the heading they issue)?

John Clonts
May 3rd 06, 07:44 PM
>On Saturday, I got an IFR clearance "KROC direct GEE direct KAGC", which
>as soon as I got airborne was ammened to "direct KAGC". I was /A and I'd
>filed along airways, but they must have known I had a handheld on board
>and it was CAVU because I couldn't have flown that in IMC with the
>equipment installed on the plane.

What does CAVU have to do with it?
--
Thanks,
John Clonts
Temple, Texas
N7NZ

Paul Tomblin
May 3rd 06, 07:46 PM
In a previous article, "John Clonts" > said:
>>On Saturday, I got an IFR clearance "KROC direct GEE direct KAGC", which
>>as soon as I got airborne was ammened to "direct KAGC". I was /A and I'd
>>filed along airways, but they must have known I had a handheld on board
>>and it was CAVU because I couldn't have flown that in IMC with the
>>equipment installed on the plane.
>
>What does CAVU have to do with it?

If the handheld had failed, I could have navigated by map reading.


--
Paul Tomblin > http://xcski.com/blogs/pt/
My hate/hate relationship with XML is, predictably, on 'hate' at the moment.
-- Matt S Trout

Robert M. Gary
May 3rd 06, 09:52 PM
> If the handheld had failed, I could have navigated by map reading.

Since direct can only be given under radar control (IFR GPS or
otherwise) if you lost your handheld you could have just asked for
vectors. I used to note "VFR GPS on board" on my IFR flight plan. I no
longer need to, ATC seems to assume everyone can take direct now. The
/G just lets them know to offer you a GPS approach.

-Robert

May 3rd 06, 10:41 PM
Tim,

All of that sounds very reasonable to me. But so many people think
that they can't navigate direct without approved panel mount GPSs that
I thought there might be some truth in it.

So if a controller asks if I can navigate direct to some intersection
(while under IFR) I can say yes and use my handheld and that's okay? I
suppose it'll all work out, but I wasn't sure how to answer that
question a month or so ago when I was asked. So I said "we can wing
it" and his response was, "well I better give you a vector" and then I
went and "augmented" his vector with my handheld. I'm sure the
controller would have preferred that I just say yes and do it. It
would have been easier for him.

Peter

Tim Auckland wrote:
> Here's my layman's understanding of this. I hope someone will jump
> in and correct me if I've got something wrong,
>
> If you're IFR en-route, ATC has three ways of directing you::
>
> a) via an airway;
> b) direct;
> c) vectors;
>
> ATC needs to have you on radar to issue (b) or (c).
>
> You should only accept a direct clearance if you're confident you can
> navigate direct.
> It doesn't matter what method you plan to use to navigate direct -- it
> can be dead reckoning, celestial navigation, visual (if you're VMC),
> VOR, hand-held GPS, panel-mount GPS, etc.
>
> If you're not confident you can navigate direct, then you should
> refuse the direct clearance. ATC already has you on radar, so it's
> typically no big deal for them to issue a radar vector instead.
>
> What happens if you've accepted a direct clearance, and your hand-held
> GPS's battereis die?
> It's just the same as any other reason for being unable to navigate
> direct (clouds cover the stars, you can no longer see your
> destination, your ham sandwich falls to the floor...). You inform
> ATC, eg:
> "Cessna 12345 is no longer able to navigate direct xyz. Request
> radar vectors."
> (Remember, they've already got you on radar to issue the direct
> clearance.)
>
> So, it's OK to accept a direct clearance, even if you're /U, as long
> as you're confident you can do the navigation.
>
> It's also good practice to always cross-check your navigation using
> some independent means.
>
> Once again, if any of this is wrong, stupid, or illegal, please
> correct me. I'm here to learn!
>
> Cheers,
>
> Tim.
>
>

Paul Tomblin
May 3rd 06, 11:04 PM
In a previous article, "Robert M. Gary" > said:
>> If the handheld had failed, I could have navigated by map reading.
>
>Since direct can only be given under radar control (IFR GPS or
>otherwise) if you lost your handheld you could have just asked for
>vectors. I used to note "VFR GPS on board" on my IFR flight plan. I no

Yeah, but in a lost comm situation, you'd either have to map read your way
to the destination or aim off to intercept your original airways course or
quickly plot a new airways course. I could do the all of the above in
CAVU, but in IMC I'd probably want to do the middle one.


--
Paul Tomblin > http://xcski.com/blogs/pt/
"The first rule of Usenet Cabal is: you do not talk about Usenet Cabal."

Robert M. Gary
May 3rd 06, 11:39 PM
> Yeah, but in a lost comm situation, you'd either have to map read your way
> to the destination or aim off to intercept your original airways course or
> quickly plot a new airways course.

Lost comm in IMC, just use the handheld. Is your concern a double
failure (handheld and comm)?

-Robert

Robert M. Gary
May 3rd 06, 11:40 PM
> So I said "we can wing it" and his response was, "well I better give you a vector" and then I
> went and "augmented" his vector with my handheld.

Often times ATC will ask you for a vector (what is your direct heading
for FOOBAR?)

-Robert

William L.Snow, PE
May 4th 06, 12:55 AM
Simply said, ifr use of vfr gps is not in the spirit of the far's.

Paul Tomblin
May 4th 06, 01:31 AM
In a previous article, "Robert M. Gary" > said:
>> Yeah, but in a lost comm situation, you'd either have to map read your way
>> to the destination or aim off to intercept your original airways course or
>> quickly plot a new airways course.
>
>Lost comm in IMC, just use the handheld. Is your concern a double
>failure (handheld and comm)?

It's already been said that you can only go direct when ATC can monitor
you on radar, so how can you go direct in a lost comm situation? If
you're lost comm, how can they vector you around traffic or warn you if
you're off track?


--
Paul Tomblin > http://xcski.com/blogs/pt/
"He passed away during an important civic function held in his honor when the
platform upon which he was standing collapsed." "I thought he was hanged?"
"That's what I said, isn't it?"

May 4th 06, 02:35 AM
Robert M. Gary wrote:
>
> Often times ATC will ask you for a vector (what is your direct heading
> for FOOBAR?)
>
> -Robert

Yeah, but that's becase they don't have FOOBAR in their computer so
they want to know what direction you'll be going so they can apply
radar separation. That's unrelated to what equipment you're navigating
with.

May 4th 06, 02:40 AM
William L.Snow, PE wrote:
> Simply said, ifr use of vfr gps is not in the spirit of the far's.

So that is why I asked the original question. Does IFR use of a
drugstore-bought calculator or a wris****ch or a sextant fall under the
same category? If not why is it different? Do you use IFR pencils to
copy your clearance on IFR paper? I'm getting silly, but in all
seriousness, where do you draw the line?

Peter

Steven P. McNicoll
May 4th 06, 03:52 AM
"Paul Tomblin" > wrote in message
...
>
> It's already been said that you can only go direct when ATC can monitor
> you on radar, so how can you go direct in a lost comm situation? If
> you're lost comm, how can they vector you around traffic or warn you if
> you're off track?
>

Then nobody should ever go direct or be vectored.

Newps
May 4th 06, 03:53 AM
wrote:
> William L.Snow, PE wrote:
>
>>Simply said, ifr use of vfr gps is not in the spirit of the far's.
>
>
> So that is why I asked the original question. Does IFR use of a
> drugstore-bought calculator or a wris****ch or a sextant fall under the
> same category?

Does the FAA have a set of regs written for a sextant? They do for the GPS.

Steven P. McNicoll
May 4th 06, 03:54 AM
"William L.Snow, PE" > wrote in message
. ..
>
> Simply said, ifr use of vfr gps is not in the spirit of the far's.

Which FARs?

Steven P. McNicoll
May 4th 06, 04:03 AM
"Newps" > wrote in message
. ..
>
> Does the FAA have a set of regs written for a sextant? They do for the
> GPS.
>

Where can that set of regs be found?

May 4th 06, 04:14 AM
Newps wrote:
> wrote:
> > William L.Snow, PE wrote:
>
> Does the FAA have a set of regs written for a sextant? They do for the GPS.

But do they have regs regarding handheld GPS units? There may be TSOs
and other stuff for panel mounts, but that has nothing to do with
handhelds. Just because both have the term "GPS" in the name doesn't
connect them in a regulatory sense. You might as well call your
handheld an "automatic sextant". Then is it okay to use while IFR? I
bet there are no regs for those.

Doug
May 4th 06, 04:20 AM
Nah, a real pilot would cross correlate the waypoint off of two VOR's,
then use the DG (that precesses mightily), set from the compass (that
swings a lot in the turbulence) to navigate to the said waypoint, so
when he gets back to the base he can give the neophytes next to the
water cooler a blow by blow account of the whole heroic deed......

Bob Noel
May 4th 06, 04:49 AM
In article om>,
wrote:

> You might as well call your
> handheld an "automatic sextant". Then is it okay to use while IFR? I
> bet there are no regs for those.

can you use a CD player while IFR? of course you can.

Can you use a PED while IFR? of course you can.

--
Bob Noel
Looking for a sig the
lawyers will hate

Roger
May 4th 06, 05:44 AM
On Wed, 3 May 2006 19:55:06 -0400, "William L.Snow, PE"
> wrote:

>Simply said, ifr use of vfr gps is not in the spirit of the far's.

Is it or isn't it? Think about it for a minute.

You can file IFR accept an IFR direct clearance by simply flying
vectors, so it matters little what you have in the plane for equipment
as long as you have the equipment necessary to make any required
approache(s)

Let's say there is a 100 miles of rain between where I am now which is
CAVU and my destination is CAVU. I have enough gas to turn around and
come back home if need be and I have only the minimum required
instruments for legally fly in IMC.

I see the storm ahead, air file, ATC gives me a vector or vectors as
need be. I come out the other side of the storm and close the flight
plan although I have in the real world had them ask that I stay with
them until the destination is in sight and VFR.

This is strictly legal when in a RADAR environment.

Now say I have my trusty 296 with me. I still file with the same
equipment suffix as I would have used without the 296. I am legal in
every sense of the FARs and in addition I have a backup hand held GPS
which I can use for my position and course and ATC is happy to have me
do so. I do not need to tell them I have GPS. I can request direct
and they can tell me cleared direct or direct when able to where ever
with out a request from me. I can accept said "cleared direct", reply
"unable, or request vectors.

Now in real life I happen to have RNAV (not GPS). I have the
equipment go from point A to point B in the system be it direct, by
vectors, or airways which meets the intent of the FARs. That I choose
to do so by following my 296 is immaterial as I have all of the
equipment in the plane to meet the equipment suffix I used when
filing.

If the internal batteries in the 296 die, and I've forgotten the
lighter plug adapter, it is my responsibility to be able to properly
fly the clearance even if it is done by requesting vectors. However I
have a panel full of *stuff* that should enable me to do so without
having to request vectors if I have been paying attention and I keep
everything set up including the ADF to watch stations along the route.

The thing I've never figured out is whey do they bother with "enroute
certified GPS" when there is no need for enroute certified GPS UNLESS
this pertains specifically to panel mounted instruments.
You don't need enroute certified anything as long as you are in RADAR
contact and you can not get a direct clearance if you are not in RADAR
contact regardless of what ever certified equipment you have..

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com

Steven P. McNicoll
May 4th 06, 11:11 AM
> wrote in message
ps.com...
>
> I've seen other discussions get off topic and go on about handheld GPS
> use under IFR. And people get all worked up about it. I know there is
> a lot of history on this newsgroup, but I haven't followed most of it
> (so don't lynch me, please).
>
> It seems that a lot of pilots believe a handheld GPS shouldn't be used
> while IFR. And a lot more believe that it can't be the "primary"
> navigation method. Sometimes that makes sense, but other times it
> doesn't (to me). So here are a few questions I have that work up to
> GPS:
>
> 1) Can you use celestial navigation while IFR?
>

Sure. The USAF has for ages.


>
> And does your sextant have to be "approved" in some way?
>

There is no such requirement in the FARs.


>
> 2) Can you use dead reckoning for IFR navigation? If so, can you use
> your wrist watch as your "primary" timer? Or does it have to be an
> "installed" clock? And to do dead reckoning calculations, can you use
> a drugstore-bought calculator? An abacus? Or how about a handy "dead
> reckoning computer" that calculates ground speed and track?
>

There is nothing in the FARs that prohibits any of that.


>
> I can understand that a handheld GPS is not supposed to be used as a
> substitute for VOR or DME or ADF (say for navigating along airways or
> for shooting instrument approaches). But can you not use one for
> flying off-airway routes without playing tricks (like pretending to
> double-check position with VOR/DME or asking ATC for a vector and then
> ignoring the heading they issue)?
>

Yes, you can. Many people insist it is illegal but none of them has been
able to find an FAR that supports that assertion. Many also insist it's a
dangerous practice, but none of them has been able to identify any hazard
induced by using a handheld GPS for enroute IFR navigation in US controlled
airspace.

gregscheetah
May 4th 06, 02:33 PM
> Since direct can only be given under radar control (IFR GPS or
> otherwise) ....

I am not sure where everyone is getting this information. Maybe it is
a 'rule' but I have often been given direct routes when out of ATC
radar and, for a while, out of ATC communications. And I don't have a
panel GPS. I use the handheld. But I always get a vector before hand,
not for legality, but in case the GPS craps out I have some idea of
what direction to fly. Yes I could look at the GPS direction, but
hearing the vector and writing it down, just enforces it into my
memory.

And I monitor VOR's to double check the path the GPS is telling me.
And I use the two VOR's to double check that they are working properly.
What the heck else do you have to do in the clouds for three hours?
Once is a while I tune in the ADF to check it. Then I monitor
intersections with the two VOR's. I may even get two radials and
triangulate my position to see how close I get to what the GPS says I
am at. And during all this I am not falling asleep.

I have had the GPS signal get lost twice during IFR flights. This
lasted for about 20 minutes. One time was not a problem with the 'box'
as I had two handhelds and the second one came up with no satellites
also. Both events were over Nebraska. So don't believe that it can
not happen. I was glad to have been on an airway both times with the
VORs set to the previous and next stations.

Greg J.

Sam Spade
May 4th 06, 02:34 PM
Robert M. Gary wrote:
>>If the handheld had failed, I could have navigated by map reading.
>
>
> Since direct can only be given under radar control (IFR GPS or
> otherwise) if you lost your handheld you could have just asked for
> vectors. I used to note "VFR GPS on board" on my IFR flight plan. I no
> longer need to, ATC seems to assume everyone can take direct now. The
> /G just lets them know to offer you a GPS approach.
>
> -Robert
>
You have to be real careful with those direct-to's in the intermountain
West, especially with a normally aspirated bird.

Jose
May 4th 06, 02:52 PM
> Many people insist it is illegal but none of them has been
> able to find an FAR that supports that assertion.

Many people also insist that as a private pilot, "holding out" is
illegal, but none of them have been able to find an FAR that supports
their assertion.

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

Sam Spade
May 4th 06, 04:14 PM
gregscheetah wrote:
>>Since direct can only be given under radar control (IFR GPS or
>>otherwise) ....
>
>
> I am not sure where everyone is getting this information. Maybe it is
> a 'rule' but I have often been given direct routes when out of ATC
> radar and, for a while, out of ATC communications.

The "rule" is that direct routes initiated by ATC are limited to the
service volume of VOR (or rarely, NDBs) and the controller can assure
that MIAs will not be violated.

When the pilot makes the request, though, let the buyer beware.

Newps
May 4th 06, 06:44 PM
Sam Spade wrote:

>
> The "rule" is that direct routes initiated by ATC are limited to the
> service volume of VOR (or rarely, NDBs) and the controller can assure
> that MIAs will not be violated.
>
> When the pilot makes the request, though, let the buyer beware.



It is irrelavant who makes the request, the rules are the same.

Newps
May 4th 06, 06:46 PM
gregscheetah wrote:

>>Since direct can only be given under radar control (IFR GPS or
>>otherwise) ....
>
>
> I am not sure where everyone is getting this information. Maybe it is
> a 'rule' but I have often been given direct routes when out of ATC
> radar and, for a while, out of ATC communications. And I don't have a
> panel GPS. I use the handheld. But I always get a vector before hand,
> not for legality, but in case the GPS craps out I have some idea of
> what direction to fly.

You're not direct, you're on a vector. If you are on a random route
you're supposed to be in radar contact, some centers don't care. Salt
Lake frequently allows aircraft to go direct for hundreds of miles
without being in radar contact.

Bob Gardner
May 4th 06, 07:29 PM
Way off topic, Jose, but take a look at this from FAA Legal Opinions:

"Dear Mr. Brock:

Re: Letter, May 12, 1987

This letter is in reply to your letter dated May 12, 1987, You describe a
proposed flight as a raffle prize for a charitable endeavor. The aircraft is
a Beechcraft Bonanza owned by a partnership. The partnership consists of
your wife and yourself. The aircraft is properly maintained. You are the
exclusive pilot of the aircraft, but your class 2 medical certificate
privileges have lapsed. The certificate, class 3 medical privileges, remain
current.
Your company raises money by various raffles, bake sales and donations
for a needy family at Christmas time. The company is not itself a charitable
organization. The fundraising is entirely voluntary and the activity is not
officially sponsored by the company.
The flight is to be a prize from a raffle. It will consist of a day or
half a day's outing, probably including lunch at Big Bear Airport or Santa
Barbara and return to Torrance Airport. There will be no compensation for
the flight except that the fuel and the luncheons will be paid from the
collected funds. You will donate all other expenses of operating the
airplane and your time. All other raffle costs in excess of fuel and
luncheon costs will be donated to the needy family.
The raffle organization will, of course, represent to the prospective
ticket purchasers that the flight is the prize, or one of the prizes for the
winner.
Section 61.118(a) of the Federal Aviation Regulations provides:
(a) A private pilot may, for compensation or hire, act as pilot in
command of an aircraft in connection with any business or employment if the
flight is only incidental to that business or employment and the aircraft
does not carry passengers or property for compensation or hire.

{p1}

As outlined above, it is our opinion that compensation for the flight
exists in two forms: (1) the direct reimbursement for fuel, and (2) the
acquisition of pilot in command time, which can be used to demonstrate
aeronautical experience eligibility for an airman certificate. With respect
to the latter form of compensation, the agency has consistently held that a
private pilot does not share the expenses of a flight with his passengers by
"donating" his pilot services, so as to fall within FAR 61.118(b). Also, the
charitable cause is not incidental to the business of the pilot, that is,
yourself, as directly related to the business enterprise, as required by FAR
61.118(a).
Additionally, the flight, as the direct inducement for the raffle
solicitation, is a charter type flight. The length of the flight removes it
from the exception provided in the applicability statement at FAR
135.1(b)(2). Even if the solicitation is conceded to be of such limited
scope as to not constitute a holding out to the public so as to constitute a
flight in air transportation, that is, common carriage, a promise is made to
the buyers of the raffle tickets to provide a service to the winners. The
service has value. In short, the flight is a flight in air commerce of
persons for compensation or hire as a commercial operator (not an air
carrier) in a small aircraft. FAR 135.1(a)(3) applies. A Part 135
certificate is required.

Sincerely,

DeWITTE T. LAWSON, JR.
Regional Counsel"

"Jose" > wrote in message
t...
>> Many people insist it is illegal but none of them has been able to find
>> an FAR that supports that assertion.
>
> Many people also insist that as a private pilot, "holding out" is illegal,
> but none of them have been able to find an FAR that supports their
> assertion.
>
> Jose
> --
> The price of freedom is... well... freedom.
> for Email, make the obvious change in the address.

Robert M. Gary
May 4th 06, 07:41 PM
> You have to be real careful with those direct-to's in the intermountain
> West, especially with a normally aspirated bird.

That's exactly why I almost never get direct. The airways do a good job
of threading the mountains for me. I wish a Garmin exec would visit out
here, perhaps then we'd get airwasy in the Garmin units.

-Robert (base of the Sierras)

Robert M. Gary
May 4th 06, 07:50 PM
> Yeah, but that's becase they don't have FOOBAR in their computer so
> they want to know what direction you'll be going so they can apply
> radar separation. That's unrelated to what equipment you're navigating
> with.

Its related to the discussion of not requiring ATC to assign you a
vector in order to go direct.

-Robert

Jose
May 4th 06, 07:58 PM
> Way off topic, Jose, but take a look at this from FAA Legal Opinions[...]

> As outlined above, it is our opinion that compensation for the flight
> exists in two forms: [...] and (2) the acquisition of pilot in
> command time, which can be used to demonstrate aeronautical
> experience eligibility for an airman certificate.

I'm aware that the FAA has decided, without making rules, what
constitutes "compensation". In my mind they are making this law up out
of whole cloth, without going through a proper rulemaking procedure.
Nonetheless, they will hang you on it.

In like manner, I am convinced the FAA will hang you on reliance (not
"use") on a handheld GPS in IMC under IFR. The FAA doesn't appear to
need to make official rules.

Thus my proposing the parallel.

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

May 4th 06, 07:59 PM
gregscheetah wrote:

> I am not sure where everyone is getting this information. Maybe it is
> a 'rule' but I have often been given direct routes when out of ATC
> radar and, for a while, out of ATC communications.

The ATC folks like to quote FAA Order 7110.65R
http://www.faa.gov/atpubs/ATC/Chp5/atc0505.html#5-5-1 which says, among
other stuff that I don't understand, that "Radar separation shall be
applied to all RNAV aircraft operating on a random (impromptu) route at
or below FL 450..."

Tim Auckland
May 4th 06, 08:10 PM
Peter,

John Deakin wrote about this on Avweb back in 1998.

Take a look at:

http://www.avweb.com/news/columns/182076-1.html

Tim.

On 3 May 2006 14:41:25 -0700, wrote:

>Tim,
>
>All of that sounds very reasonable to me. But so many people think
>that they can't navigate direct without approved panel mount GPSs that
>I thought there might be some truth in it.
>
>So if a controller asks if I can navigate direct to some intersection
>(while under IFR) I can say yes and use my handheld and that's okay? I
>suppose it'll all work out, but I wasn't sure how to answer that
>question a month or so ago when I was asked. So I said "we can wing
>it" and his response was, "well I better give you a vector" and then I
>went and "augmented" his vector with my handheld. I'm sure the
>controller would have preferred that I just say yes and do it. It
>would have been easier for him.
>
>Peter
>
>Tim Auckland wrote:
>> Here's my layman's understanding of this. I hope someone will jump
>> in and correct me if I've got something wrong,
>>
>> If you're IFR en-route, ATC has three ways of directing you::
>>
>> a) via an airway;
>> b) direct;
>> c) vectors;
>>
>> ATC needs to have you on radar to issue (b) or (c).
>>
>> You should only accept a direct clearance if you're confident you can
>> navigate direct.
>> It doesn't matter what method you plan to use to navigate direct -- it
>> can be dead reckoning, celestial navigation, visual (if you're VMC),
>> VOR, hand-held GPS, panel-mount GPS, etc.
>>
>> If you're not confident you can navigate direct, then you should
>> refuse the direct clearance. ATC already has you on radar, so it's
>> typically no big deal for them to issue a radar vector instead.
>>
>> What happens if you've accepted a direct clearance, and your hand-held
>> GPS's battereis die?
>> It's just the same as any other reason for being unable to navigate
>> direct (clouds cover the stars, you can no longer see your
>> destination, your ham sandwich falls to the floor...). You inform
>> ATC, eg:
>> "Cessna 12345 is no longer able to navigate direct xyz. Request
>> radar vectors."
>> (Remember, they've already got you on radar to issue the direct
>> clearance.)
>>
>> So, it's OK to accept a direct clearance, even if you're /U, as long
>> as you're confident you can do the navigation.
>>
>> It's also good practice to always cross-check your navigation using
>> some independent means.
>>
>> Once again, if any of this is wrong, stupid, or illegal, please
>> correct me. I'm here to learn!
>>
>> Cheers,
>>
>> Tim.
>>
>>

Sam Spade
May 4th 06, 09:41 PM
Newps wrote:
>
>
> Sam Spade wrote:
>
>>
>> The "rule" is that direct routes initiated by ATC are limited to the
>> service volume of VOR (or rarely, NDBs) and the controller can assure
>> that MIAs will not be violated.
>>
>> When the pilot makes the request, though, let the buyer beware.
>
>
>
>
> It is irrelavant who makes the request, the rules are the same.

That's sure what is says on paper. Still, let the "buyer beware" when
he makes the request.

Tim Auckland
May 4th 06, 10:41 PM
Newps,

If using a hand-held GPS as a significant IFR navigation tool is
against the spirit of the FARs, surely the FAA could put an end to the
practice very simply by strongly discouraging controllers from issuing
Direct-To clearances to /A and /U aircraft
(unless of course it's Direct-To a ground-based navaid and the plane
is within the service volume of the navaid).

It doesn't appear to have done so, even though the debate has been
going on since at least 1998.

I'd be very much interested in any insights you might be able to share
regarding the FAA's behavior here.

(As I said earlier, I'm here to learn.)

Regards,

Tim.



On Thu, 04 May 2006 11:46:11 -0600, Newps > wrote:

>
>
>gregscheetah wrote:
>
>>>Since direct can only be given under radar control (IFR GPS or
>>>otherwise) ....
>>
>>
>> I am not sure where everyone is getting this information. Maybe it is
>> a 'rule' but I have often been given direct routes when out of ATC
>> radar and, for a while, out of ATC communications. And I don't have a
>> panel GPS. I use the handheld. But I always get a vector before hand,
>> not for legality, but in case the GPS craps out I have some idea of
>> what direction to fly.
>
>You're not direct, you're on a vector. If you are on a random route
>you're supposed to be in radar contact, some centers don't care. Salt
>Lake frequently allows aircraft to go direct for hundreds of miles
>without being in radar contact.

Newps
May 4th 06, 11:01 PM
Tim Auckland wrote:
> Newps,
>
> If using a hand-held GPS as a significant IFR navigation tool is
> against the spirit of the FARs, surely the FAA could put an end to the
> practice very simply by strongly discouraging controllers from issuing
> Direct-To clearances to /A and /U aircraft

It's already there, the controller simply needs to read the book.


>
> It doesn't appear to have done so, even though the debate has been
> going on since at least 1998.

It's like anything else in the FAA, they don't care until you wreck
something. Then the FAA will buy part or all of your airplane when you sue.

ted
May 4th 06, 11:57 PM
"Doug" > wrote in message
oups.com...
> Nah, a real pilot would cross correlate the waypoint off of two VOR's,
> then use the DG (that precesses mightily), set from the compass (that
> swings a lot in the turbulence) to navigate to the said waypoint, so
> when he gets back to the base he can give the neophytes next to the
> water cooler a blow by blow account of the whole heroic deed......
>

Doug, you sound like one of the few on this group who actually know how to
fly.

Tim Auckland
May 5th 06, 12:11 AM
Interesting. Thanks.

On Thu, 04 May 2006 16:01:11 -0600, Newps > wrote:

>
>
>Tim Auckland wrote:
>> Newps,
>>
>> If using a hand-held GPS as a significant IFR navigation tool is
>> against the spirit of the FARs, surely the FAA could put an end to the
>> practice very simply by strongly discouraging controllers from issuing
>> Direct-To clearances to /A and /U aircraft
>
>It's already there, the controller simply needs to read the book.
>
>
>>
>> It doesn't appear to have done so, even though the debate has been
>> going on since at least 1998.
>
>It's like anything else in the FAA, they don't care until you wreck
>something. Then the FAA will buy part or all of your airplane when you sue.

Sam Spade
May 5th 06, 02:27 AM
Newps wrote:
>
>
> Tim Auckland wrote:
>
>> Newps,
>>
>> If using a hand-held GPS as a significant IFR navigation tool is
>> against the spirit of the FARs, surely the FAA could put an end to the
>> practice very simply by strongly discouraging controllers from issuing
>> Direct-To clearances to /A and /U aircraft
>
>
> It's already there, the controller simply needs to read the book.
>
>
>>
>> It doesn't appear to have done so, even though the debate has been
>> going on since at least 1998.
>
>
> It's like anything else in the FAA, they don't care until you wreck
> something. Then the FAA will buy part or all of your airplane when you
> sue.
>

And, part of the "they" is the controller workforce, except they don't
pay any part of the settlement.

Sam Spade
May 5th 06, 02:32 AM
You are not allowed to use an IFR-certified GPS for en route (domestic
airspace) in a non-radar environment except with the special Alaska
provisions.

The fact that ATC may clear you via direct via RNAV when non-radar does
not relieve you of your regulatory responsibilites.

Roger wrote:

> On Wed, 3 May 2006 19:55:06 -0400, "William L.Snow, PE"
> > wrote:
>
>
>>Simply said, ifr use of vfr gps is not in the spirit of the far's.
>
>
> Is it or isn't it? Think about it for a minute.
>
> You can file IFR accept an IFR direct clearance by simply flying
> vectors, so it matters little what you have in the plane for equipment
> as long as you have the equipment necessary to make any required
> approache(s)
>
> Let's say there is a 100 miles of rain between where I am now which is
> CAVU and my destination is CAVU. I have enough gas to turn around and
> come back home if need be and I have only the minimum required
> instruments for legally fly in IMC.
>
> I see the storm ahead, air file, ATC gives me a vector or vectors as
> need be. I come out the other side of the storm and close the flight
> plan although I have in the real world had them ask that I stay with
> them until the destination is in sight and VFR.
>
> This is strictly legal when in a RADAR environment.
>
> Now say I have my trusty 296 with me. I still file with the same
> equipment suffix as I would have used without the 296. I am legal in
> every sense of the FARs and in addition I have a backup hand held GPS
> which I can use for my position and course and ATC is happy to have me
> do so. I do not need to tell them I have GPS. I can request direct
> and they can tell me cleared direct or direct when able to where ever
> with out a request from me. I can accept said "cleared direct", reply
> "unable, or request vectors.
>
> Now in real life I happen to have RNAV (not GPS). I have the
> equipment go from point A to point B in the system be it direct, by
> vectors, or airways which meets the intent of the FARs. That I choose
> to do so by following my 296 is immaterial as I have all of the
> equipment in the plane to meet the equipment suffix I used when
> filing.
>
> If the internal batteries in the 296 die, and I've forgotten the
> lighter plug adapter, it is my responsibility to be able to properly
> fly the clearance even if it is done by requesting vectors. However I
> have a panel full of *stuff* that should enable me to do so without
> having to request vectors if I have been paying attention and I keep
> everything set up including the ADF to watch stations along the route.
>
> The thing I've never figured out is whey do they bother with "enroute
> certified GPS" when there is no need for enroute certified GPS UNLESS
> this pertains specifically to panel mounted instruments.
> You don't need enroute certified anything as long as you are in RADAR
> contact and you can not get a direct clearance if you are not in RADAR
> contact regardless of what ever certified equipment you have..
>
> Roger Halstead (K8RI & ARRL life member)
> (N833R, S# CD-2 Worlds oldest Debonair)
> www.rogerhalstead.com

Sam Spade
May 5th 06, 02:35 AM
Jose wrote:

>> Way off topic, Jose, but take a look at this from FAA Legal Opinions[...]
>
>
>> As outlined above, it is our opinion that compensation for the flight
>> exists in two forms: [...] and (2) the acquisition of pilot in
>> command time, which can be used to demonstrate aeronautical
>> experience eligibility for an airman certificate.
>
>
> I'm aware that the FAA has decided, without making rules, what
> constitutes "compensation". In my mind they are making this law up out
> of whole cloth, without going through a proper rulemaking procedure.
> Nonetheless, they will hang you on it.
>
> In like manner, I am convinced the FAA will hang you on reliance (not
> "use") on a handheld GPS in IMC under IFR. The FAA doesn't appear to
> need to make official rules.
>
> Thus my proposing the parallel.
>
> Jose

A legal interp has the full force and effect of regulation. Keep in
mind, FARs are federal civil law, so the FAA, like the IRS (in
non-criminal tax cases) holds more cards than the "taxpayer."

Newps
May 5th 06, 03:13 AM
Sam Spade wrote:

>>
>
> And, part of the "they" is the controller workforce, except they don't
> pay any part of the settlement.

They is the US taxpayer. I cannot be sued.

Roger
May 5th 06, 03:55 AM
On Thu, 04 May 2006 13:41:13 -0700, Sam Spade >
wrote:

>Newps wrote:
>>
>>
>> Sam Spade wrote:
>>
>>>
>>> The "rule" is that direct routes initiated by ATC are limited to the
>>> service volume of VOR (or rarely, NDBs) and the controller can assure
>>> that MIAs will not be violated.
>>>
>>> When the pilot makes the request, though, let the buyer beware.
>>
>>
>>
>>
>> It is irrelavant who makes the request, the rules are the same.
>
>That's sure what is says on paper. Still, let the "buyer beware" when
>he makes the request.

Why?

I regularly file, 3BS direct LDM (94 miles), Direct MTW(55 miles),
Direct OSH (39 miles). Coming home I file the reverse but still direct
Each is in a different sector. 3BS (Cleveland Center) is an airport,
LMD(Minneapolis Center) is an NDB, MTW (Green Bay?) is a VOR, and OSH
is both an airport and VOR (Chicago)

Altitudes vary between 5,000 and 8,000 although I have been sent
higher on occasion.

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com

Roger
May 5th 06, 07:03 AM
On Thu, 04 May 2006 18:58:22 GMT, Jose >
wrote:

>> Way off topic, Jose, but take a look at this from FAA Legal Opinions[...]
>
>> As outlined above, it is our opinion that compensation for the flight
>> exists in two forms: [...] and (2) the acquisition of pilot in
>> command time, which can be used to demonstrate aeronautical
>> experience eligibility for an airman certificate.

I wonder what they'd say in my case as more hours wouldn't qualify me
for anything including ratings.

>I'm aware that the FAA has decided, without making rules, what
>constitutes "compensation". In my mind they are making this law up out
>of whole cloth, without going through a proper rulemaking procedure.
>Nonetheless, they will hang you on it.
>
>In like manner, I am convinced the FAA will hang you on reliance (not

They can "hang" you for relying on anything to the exclusion of
something else. IE ... fixation. He was neglecting his scan and
fixating on the AI, or altimeter, or making sure his passenger had
their head in the "lunch bag", or he was watching the left wing as it
broke off instead of flying the airplane, or maybe someone heard the
pilot wasn't feeling good so he/she must have been flying when they
shouldn't.

I'm firmly of the opinion that any time something important breaks I
should be some where else.


Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com
>"use") on a handheld GPS in IMC under IFR. The FAA doesn't appear to
>need to make official rules.
>
>Thus my proposing the parallel.
>
>Jose

Sam Spade
May 5th 06, 10:36 AM
Newps wrote:
>
>
> Sam Spade wrote:
>
>>>
>>
>> And, part of the "they" is the controller workforce, except they don't
>> pay any part of the settlement.
>
>
> They is the US taxpayer. I cannot be sued.

You said previously "they don't care until you wreck something." I took
that to mean the FAA, given the context. The taxpayers aren't sued in
any case; it's the government.

Sam Spade
May 5th 06, 10:40 AM
Roger wrote:

> On Thu, 04 May 2006 13:41:13 -0700, Sam Spade >
> wrote:
>
>
>>Newps wrote:
>>
>>>
>>>Sam Spade wrote:
>>>
>>>
>>>>The "rule" is that direct routes initiated by ATC are limited to the
>>>>service volume of VOR (or rarely, NDBs) and the controller can assure
>>>>that MIAs will not be violated.
>>>>
>>>>When the pilot makes the request, though, let the buyer beware.
>>>
>>>
>>>
>>>
>>>It is irrelavant who makes the request, the rules are the same.
>>
>>That's sure what is says on paper. Still, let the "buyer beware" when
>>he makes the request.
>
>
> Why?
>
My caution applies primarily in the Western DMA. You are home free in
the middle of the country above 4,000, or so, and 8,000, or so in the
Eastern DMA. In the Western DMA there are airways a whole lot lower
than areas between them.

150flivver
May 5th 06, 01:44 PM
In navigator training back when we actually used a sextant, whenever
our mission called for legs using celestial navigation ATC would give
us a celnav clearance. This allowed us much more airspace than a
"direct" clearance as celestial nav was less precise than other methods
of navigation. On missions which required students to use only ded
reckoning, the pilot would also ask ATC for a celnav clearance in order
to have the freedom to manuever (i.e. wander) off the direct line to
the next turnpoint. Thus, when ATC sends you direct to a point, they
expect you to be pretty darn close to staying on the direct course to
that point. If you decide that your going to use a watch and compass
(dr) or pull out a sextant and you wander significantly off that
straight line and stray into restricted airspace--guess who's going to
get violated?

Dave Butler
May 5th 06, 02:03 PM
> You are not allowed to use an IFR-certified GPS for en route (domestic
> airspace) in a non-radar environment except with the special Alaska
> provisions.

Perhaps you meant to say you're not allowed to fly off-airway?

If you really meant what you said, please explain / cite the rule.

Dave Butler
May 5th 06, 02:05 PM
> My caution applies primarily in the Western DMA. You are home free in
> the middle of the country above 4,000, or so, and 8,000, or so in the
> Eastern DMA. In the Western DMA there are airways a whole lot lower
> than areas between them.

DMA?

Tim Auckland
May 5th 06, 05:44 PM
Newps,

By "the book" do you mean 7110.65R?
http://www.faa.gov/atpubs/ATC/index.htm

I was browsing this online last night and couldn't find the reference,
but that's hardly surprising given that it's the first time I've ever
looked at this tome.

Any chance you could provide a link or reference?

Many thanks,

Tim.

On Thu, 04 May 2006 16:01:11 -0600, Newps > wrote:

>
>
>Tim Auckland wrote:
>> Newps,
>>
>> If using a hand-held GPS as a significant IFR navigation tool is
>> against the spirit of the FARs, surely the FAA could put an end to the
>> practice very simply by strongly discouraging controllers from issuing
>> Direct-To clearances to /A and /U aircraft
>
>It's already there, the controller simply needs to read the book.
>
>
>>
>> It doesn't appear to have done so, even though the debate has been
>> going on since at least 1998.
>
>It's like anything else in the FAA, they don't care until you wreck
>something. Then the FAA will buy part or all of your airplane when you sue.

Newps
May 5th 06, 06:19 PM
Sam Spade wrote:

>>
>> They is the US taxpayer. I cannot be sued.
>
>
> You said previously "they don't care until you wreck something." I took
> that to mean the FAA, given the context. The taxpayers aren't sued in
> any case; it's the government.

Right, it wasn't your money to start with.

Newps
May 5th 06, 06:25 PM
Tim Auckland wrote:

> Newps,
>
> By "the book" do you mean 7110.65R?
> http://www.faa.gov/atpubs/ATC/index.htm
>
> I was browsing this online last night and couldn't find the reference,
> but that's hardly surprising given that it's the first time I've ever
> looked at this tome.

It's a ridiculous piece of work as you saw. If you could clear anybody
direct an equipment suffix would be unnecessary. It's also a shared
thing. I have my rules, you have yours. You have to be able to fly
what you file. You'd be suprised to find out how many operators file a
direct clearance as a /A or /Q and then say they need a vector. Even
when it is legal because they would be within the service volume.

Jose
May 5th 06, 06:58 PM
> You'd be suprised to find out how many operators file a direct clearance as a /A or /Q and then say they need a vector.

Well, one reason for that (at least on the East coast) is that it
doesn't really matter what you file, you will get something different.
So why bother figuring out a routing you won't use anyway.

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

Newps
May 5th 06, 07:07 PM
Jose wrote:
>> You'd be suprised to find out how many operators file a direct
>> clearance as a /A or /Q and then say they need a vector.
>
>
> Well, one reason for that (at least on the East coast) is that it
> doesn't really matter what you file, you will get something different.
> So why bother figuring out a routing you won't use anyway.


NORDO

Jose
May 5th 06, 07:21 PM
>> Well, one reason for that (at least on the East coast) is that it doesn't really matter what you file, you will get something different. So why bother figuring out a routing you won't use anyway.
> NORDO

That's not a reason. You will get a clearance, and you need to reject a
clearance you can't fly. But figuring out a route you won't get doesn't
address the route you -do- get.

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

Sam Spade
May 6th 06, 12:25 AM
Dave Butler wrote:
>
>> My caution applies primarily in the Western DMA. You are home free in
>> the middle of the country above 4,000, or so, and 8,000, or so in the
>> Eastern DMA. In the Western DMA there are airways a whole lot lower
>> than areas between them.
>
>
> DMA?

Designated Mountainous Area

Sam Spade
May 6th 06, 12:26 AM
Newps wrote:

>
>
> Sam Spade wrote:
>
>>>
>>> They is the US taxpayer. I cannot be sued.
>>
>>
>>
>> You said previously "they don't care until you wreck something." I
>> took that to mean the FAA, given the context. The taxpayers aren't
>> sued in any case; it's the government.
>
>
> Right, it wasn't your money to start with.
>
If I have that kind of control, then please give me back my money.

Sam Spade
May 6th 06, 12:42 AM
Dave Butler wrote:

>
>> You are not allowed to use an IFR-certified GPS for en route (domestic
>> airspace) in a non-radar environment except with the special Alaska
>> provisions.
>
>
> Perhaps you meant to say you're not allowed to fly off-airway?
>
> If you really meant what you said, please explain / cite the rule.

Part 95, IFR Altitudes establishes MEAs and is the authority for airways
and Jet Routes. Those airways are rules, just like an instrument
approach procedure is a rule.

With instrument approach procedures (in addition to RNAV/GPS IAPs) you
have VOR and NBD IAPs that are approved for overlay flight with GPS.
That is the authorization to substitute GPS for VOR, where authorized on
the chart.

You don't have any overlay (i.e., standalone, non-radar) authorization
fo Victor Airways or Jet Routes. Thus, if you are not in a radar
environment you cannot use RNAV as primary for Victor airways or Jet Routes.

Does anyone care? Only if something goes wrong.

There are a few Q Routes, which are predicated solely on RNAV, but thus
far they have been established where traffic volumne is high and radar
is available. They are pretty much for the airlines in the lower 48,
thus far. And, I believe they are all in the high altitude stratum.

As I said before, Alaska has a special authorization that specifically
permits GPS/RNAV overlay of Victor airways.

Steven P. McNicoll
May 6th 06, 03:09 PM
"Sam Spade" > wrote in message
news:nTo6g.175187$bm6.57868@fed1read04...
>
> The "rule" is that direct routes initiated by ATC are limited to the
> service volume of VOR (or rarely, NDBs) and the controller can assure that
> MIAs will not be violated.
>
> When the pilot makes the request, though, let the buyer beware.
>

That's not correct. NAVAID usable distance limits are based on MSL
altitudes, service volumes are based on AGL altitudes. It doesn't matter if
the routing is initiated by ATC or requested by the pilot, radar monitoring
is required when operating outside of the specified altitude and distance
limitations in controlled airspace unless approval has been obtained from
the Frequency Management and Flight Inspection Offices to exceed them or the
requested routing is via an MTR.

Sam Spade
May 6th 06, 04:25 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:nTo6g.175187$bm6.57868@fed1read04...
>
>>The "rule" is that direct routes initiated by ATC are limited to the
>>service volume of VOR (or rarely, NDBs) and the controller can assure that
>>MIAs will not be violated.
>>
>>When the pilot makes the request, though, let the buyer beware.
>>
>
>
> That's not correct. NAVAID usable distance limits are based on MSL
> altitudes, service volumes are based on AGL altitudes. It doesn't matter if
> the routing is initiated by ATC or requested by the pilot, radar monitoring
> is required when operating outside of the specified altitude and distance
> limitations in controlled airspace unless approval has been obtained from
> the Frequency Management and Flight Inspection Offices to exceed them or the
> requested routing is via an MTR.
>
>

What did I say that is not correct, and inconsistent with 7110.65 4-1-1?

Steven P. McNicoll
May 6th 06, 05:02 PM
"Sam Spade" > wrote in message
news:Nd37g.175259$bm6.25645@fed1read04...
>
> What did I say that is not correct, and inconsistent with 7110.65 4-1-1?
>

"The 'rule' is that direct routes initiated by ATC are limited to the
service volume of VOR (or rarely, NDBs) and the controller can assure that
MIAs will not be violated."

Sam Spade
May 6th 06, 06:51 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:Nd37g.175259$bm6.25645@fed1read04...
>
>>What did I say that is not correct, and inconsistent with 7110.65 4-1-1?
>>
>
>
> "The 'rule' is that direct routes initiated by ATC are limited to the
> service volume of VOR (or rarely, NDBs) and the controller can assure that
> MIAs will not be violated."
>
>

What in the following 7110.65 instruction is inconsistant with what I
stated?

4-1-1. ALTITUDE AND DISTANCE LIMITATIONS
When specifying a route other than an established airway or route, do
not exceed the limitations in the table on any portion of the route
which lies within controlled airspace. (For altitude and distance
limitations, see TBL 4-1-1, TBL 4-1-2, TBL 4-1-3, and TBL 4-1-4.) (For
correct application of altitude and distance limitations see FIG 4-1-1
and FIG 4-1-2.)


TBL 4-1-1 - VOR/VORTAC/TACAN NAVAIDs
Normal Usable Altitudes and Radius Distances
Class Altitude Distance (miles)
T 12,000 and below 25
L Below 18,000 40
H Below 14,500 40
H 14,500 - 17,999 100
H 18,000 - FL 450 130
H Above FL 450 100

Steven P. McNicoll
May 6th 06, 10:00 PM
"Sam Spade" > wrote in message
news:2n57g.175262$bm6.158095@fed1read04...
>
> What in the following 7110.65 instruction is inconsistant with what I
> stated?
>
> 4-1-1. ALTITUDE AND DISTANCE LIMITATIONS
> When specifying a route other than an established airway or route, do not
> exceed the limitations in the table on any portion of the route which lies
> within controlled airspace. (For altitude and distance limitations, see
> TBL 4-1-1, TBL 4-1-2, TBL 4-1-3, and TBL 4-1-4.) (For correct application
> of altitude and distance limitations see FIG 4-1-1 and FIG 4-1-2.)
>
>
> TBL 4-1-1 - VOR/VORTAC/TACAN NAVAIDs
> Normal Usable Altitudes and Radius Distances Class Altitude Distance
> (miles) T 12,000 and below 25 L Below 18,000 40 H Below 14,500 40 H
> 14,500 - 17,999 100 H 18,000 - FL 450 130 H Above FL 450 100


TBL 4-1-1 - VOR/VORTAC/TACAN NAVAIDs

Normal Usable Altitudes and Radius Distances
Class Altitude Distance (miles)
T 12,000 and below 25
L Below 18,000 40
H Below 14,500 40
H 14,500 - 17,999 100
H 18,000 - FL 450 130
H Above FL 450 100

Sam Spade
May 7th 06, 02:16 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:2n57g.175262$bm6.158095@fed1read04...
>
>>What in the following 7110.65 instruction is inconsistant with what I
>>stated?
>>
>>4-1-1. ALTITUDE AND DISTANCE LIMITATIONS
>>When specifying a route other than an established airway or route, do not
>>exceed the limitations in the table on any portion of the route which lies
>>within controlled airspace. (For altitude and distance limitations, see
>>TBL 4-1-1, TBL 4-1-2, TBL 4-1-3, and TBL 4-1-4.) (For correct application
>>of altitude and distance limitations see FIG 4-1-1 and FIG 4-1-2.)
>>
>>
>>TBL 4-1-1 - VOR/VORTAC/TACAN NAVAIDs
>>Normal Usable Altitudes and Radius Distances Class Altitude Distance
>>(miles) T 12,000 and below 25 L Below 18,000 40 H Below 14,500 40 H
>>14,500 - 17,999 100 H 18,000 - FL 450 130 H Above FL 450 100
>
>
>
> TBL 4-1-1 - VOR/VORTAC/TACAN NAVAIDs
>
> Normal Usable Altitudes and Radius Distances
> Class Altitude Distance (miles)
> T 12,000 and below 25
> L Below 18,000 40
> H Below 14,500 40
> H 14,500 - 17,999 100
> H 18,000 - FL 450 130
> H Above FL 450 100
>
>
Well, gee wiz, you're better with tabs than I am.

Nonetheless, the references both you and I cite are identical.

So, you didn't answer my question, except to implicitly admit you are
wrong on substance. (ye gads!)

Steven P. McNicoll
May 7th 06, 02:36 AM
"Sam Spade" > wrote in message
news:KTb7g.175481$bm6.106495@fed1read04...
>
> Well, gee wiz, you're better with tabs than I am.
>

Among many other things, I'm sure.


>
> Nonetheless, the references both you and I cite are identical.
>

I didn't cite a reference, I just answered your questions.


>
> So, you didn't answer my question, except to implicitly admit you are
> wrong on substance. (ye gads!)
>


Actually, I did answer your question, twice. You're just too dim to realize
it.

You wrote, some time ago now; "The 'rule' is that direct routes initiated by
ATC are limited to the service volume of VOR (or rarely, NDBs) and the
controller can assure that
MIAs will not be violated." The "rule" has nothing to do with service
volumes. NAVAID usable distance limits in FAAO 7110.65 are based on MSL
altitudes and flight levels, service volumes are based on AGL altitudes.

Is the bulb any brighter now?

Steven P. McNicoll
May 7th 06, 02:48 AM
"Newps" > wrote in message
. ..
>
> If you are on a random route
> you're supposed to be in radar contact, some centers don't care. Salt
> Lake frequently allows aircraft to go direct for hundreds of miles without
> being in radar contact.
>

An ARTCC is an entity incapable of caring. Some controllers are just poorly
trained, they don't know any better. Standards have fallen rather sharply
in the last fifteen years or so.

Steven P. McNicoll
May 7th 06, 03:34 AM
"Newps" > wrote in message
...
>
> It's already there, the controller simply needs to read the book.
>

There is nothing at all like that in FAAO 7110.65. Nor should there be.

Steven P. McNicoll
May 7th 06, 03:34 AM
> wrote in message
oups.com...
>
> The ATC folks like to quote FAA Order 7110.65R
> http://www.faa.gov/atpubs/ATC/Chp5/atc0505.html#5-5-1 which says, among
> other stuff that I don't understand, that "Radar separation shall be
> applied to all RNAV aircraft operating on a random (impromptu) route at
> or below FL 450..."
>

You're in the wrong chapter. See paragraphs 4-1-1 and 4-1-2 at the link
below:

http://www.faa.gov/atpubs/ATC/Chp4/atc0401.html

Steven P. McNicoll
May 7th 06, 03:35 AM
"Sam Spade" > wrote in message
news:2Xx6g.175203$bm6.65816@fed1read04...
>
> You are not allowed to use an IFR-certified GPS for en route (domestic
> airspace) in a non-radar environment except with the special Alaska
> provisions.
>

Nonsense.

Steven P. McNicoll
May 7th 06, 03:35 AM
"Sam Spade" > wrote in message
news:iZx6g.175204$bm6.170325@fed1read04...
>
> A legal interp has the full force and effect of regulation.
>

It does not.

Steven P. McNicoll
May 7th 06, 03:37 AM
"Tim Auckland" > wrote in message
...
>
> If using a hand-held GPS as a significant IFR navigation tool is
> against the spirit of the FARs, surely the FAA could put an end to the
> practice very simply by strongly discouraging controllers from issuing
> Direct-To clearances to /A and /U aircraft
> (unless of course it's Direct-To a ground-based navaid and the plane
> is within the service volume of the navaid).
>
> It doesn't appear to have done so, even though the debate has been
> going on since at least 1998.
>

Why make it the controller's responsibility? If the FAA wanted to make IFR
use of handheld GPS illegal all they'd have to do is create an FAR
prohibiting it. Something like:

No person may operate a civil aircraft under IFR using an Area Navigation
System unless the equipment of that aircraft meets the requirements of
TSO-C60b, TSO-C115b, or TSO-C129A and is installed in accordance with AC
20-121, AC 20-130, or AC 20-138.

Bob Noel
May 7th 06, 03:52 AM
In article >,
"Steven P. McNicoll" > wrote:

> No person may operate a civil aircraft under IFR using an Area Navigation
> System unless the equipment of that aircraft meets the requirements of
> TSO-C60b, TSO-C115b, or TSO-C129A and is installed in accordance with AC
> 20-121, AC 20-130, or AC 20-138.

wait for RNP.

And how many AC's are referenced in the FARs?

--
Bob Noel
Looking for a sig the
lawyers will hate

Steven P. McNicoll
May 7th 06, 04:19 AM
"Tim Auckland" > wrote in message
...
>
> By "the book" do you mean 7110.65R?
> http://www.faa.gov/atpubs/ATC/index.htm
>
> I was browsing this online last night and couldn't find the reference,
> but that's hardly surprising given that it's the first time I've ever
> looked at this tome.
>
> Any chance you could provide a link or reference?
>

No, he can't, as there is no such rule.

Steven P. McNicoll
May 7th 06, 04:19 AM
"Roger" > wrote in message
...
>
> Why?
>
> I regularly file, 3BS direct LDM (94 miles), Direct MTW(55 miles),
> Direct OSH (39 miles). Coming home I file the reverse but still direct
> Each is in a different sector. 3BS (Cleveland Center) is an airport,
> LMD(Minneapolis Center) is an NDB, MTW (Green Bay?) is a VOR, and OSH
> is both an airport and VOR (Chicago)
>
> Altitudes vary between 5,000 and 8,000 although I have been sent
> higher on occasion.
>

It appears all of that route is within radar coverage at those altitudes. I
don't see your point.

Steven P. McNicoll
May 7th 06, 04:27 AM
"150flivver" > wrote in message
oups.com...
>
> In navigator training back when we actually used a sextant, whenever
> our mission called for legs using celestial navigation ATC would give
> us a celnav clearance. This allowed us much more airspace than a
> "direct" clearance as celestial nav was less precise than other methods
> of navigation.
>

Yes, but probably not as less precise as you think!

Steven P. McNicoll
May 7th 06, 04:27 AM
"Paul Tomblin" > wrote in message
...
>
> It's already been said that you can only go direct when ATC can monitor
> you on radar, so how can you go direct in a lost comm situation? If
> you're lost comm, how can they vector you around traffic or warn you if
> you're off track?
>

It's no different than losing comm while on a long range vector. Nobody
claims that's illegal, few claim it's hazardous, and many insist that's what
you're really doing while navigating by handheld GPS.

Steven P. McNicoll
May 7th 06, 04:27 AM
"Sam Spade" > wrote in message
news:J4F6g.175209$bm6.131782@fed1read04...
>
> My caution applies primarily in the Western DMA. You are home free in the
> middle of the country above 4,000, or so, and 8,000, or so in the Eastern
> DMA. In the Western DMA there are airways a whole lot lower than areas
> between them.
>

An MIA applies to the areas between them.

Steven P. McNicoll
May 7th 06, 04:27 AM
"Sam Spade" > wrote in message
news:MpR6g.175231$bm6.132922@fed1read04...
>
> Part 95, IFR Altitudes establishes MEAs and is the authority for airways
> and Jet Routes. Those airways are rules, just like an instrument approach
> procedure is a rule.
>
> With instrument approach procedures (in addition to RNAV/GPS IAPs) you
> have VOR and NBD IAPs that are approved for overlay flight with GPS. That
> is the authorization to substitute GPS for VOR, where authorized on the
> chart.
>
> You don't have any overlay (i.e., standalone, non-radar) authorization fo
> Victor Airways or Jet Routes. Thus, if you are not in a radar environment
> you cannot use RNAV as primary for Victor airways or Jet Routes.
>
> Does anyone care? Only if something goes wrong.
>
> There are a few Q Routes, which are predicated solely on RNAV, but thus
> far they have been established where traffic volumne is high and radar is
> available. They are pretty much for the airlines in the lower 48, thus
> far. And, I believe they are all in the high altitude stratum.
>
> As I said before, Alaska has a special authorization that specifically
> permits GPS/RNAV overlay of Victor airways.
>

You haven't cited a rule.

Steven P. McNicoll
May 7th 06, 04:35 AM
"Bob Noel" > wrote in message
...
>
> And how many AC's are referenced in the FARs?
>

I don't know. You'll have to count them yourself.

Dane Spearing
May 7th 06, 04:51 AM
So, the initial purpose of this thread was to discuss whether or not one
could use a handheld GPS for IFR navigation. Lots of people have been
tossing around lots of opinions with little or no references to rules or
guidance to back them up (hardly surprising...this is usenet after all...)

Anyway, for my own personal edification and enlightenment, I went and
tracked down the official FAA Advisory Circular that specifies what
the requirements are for the use of GPS under IFR. It's entitled
"Airworthiness Approval of Navigation or Flight Management Systems
Integrating Multiple Navigation Sensors", and is FAA AC 20-130A.
It's about as exciting to read as the dictionary (again, hardly
surprising). However, the Gleim Instrument Pilot Flight Manueuvers and
Practical Test Prep guide (which is where I found the reference in the
first place) does a nice job of summarizing the requirements for use of
GPS under IFR as specified in AC 20-130A. It states:

Authorization to conduct any GPS operation under IFR requires that:
a) GPS navigation equipment used must be FAA-approved and the installation
must be done in accordance with FAA requirements
i) Approval for the use of the GPS for IFR operations, and any
limitations, will be found in the airplane's POH (also called
the FAA-approved Airplane Flight Manual) and the airplane's
logbook
ii) VFR and hand-held GPS systems are not authorized for IFR
navigation, for instrument approaches, or as a principle
instrument flight references. During IFR operations, they
may be considered only an aid to situational awareness.

Aircraft using GPS navigation equipment under IFR must be equipped with an
approved and operational alternate means of navigation appropriate to the
flight.
a) Active monitoring of the alternative navigation equipment is not required
if the GPS receiver uses RAIM for integrity monitoring.
b) Active monitoring of the alternative navigation equipment is required
when the RAIM capability of the GPS equipment is lost.

This seems fairly clear to me.....

-- Dane

Bob Noel
May 7th 06, 06:49 AM
In article >,
"Steven P. McNicoll" > wrote:

> > And how many AC's are referenced in the FARs?
>
> I don't know. You'll have to count them yourself.

can you find even one?

--
Bob Noel
Looking for a sig the
lawyers will hate

May 7th 06, 07:25 AM
Steven P. McNicoll wrote:
> > wrote in message
> oups.com...
> >
> > The ATC folks like to quote FAA Order 7110.65R
> > http://www.faa.gov/atpubs/ATC/Chp5/atc0505.html#5-5-1 which says, among
> > other stuff that I don't understand, that "Radar separation shall be
> > applied to all RNAV aircraft operating on a random (impromptu) route at
> > or below FL 450..."
> >
>
> You're in the wrong chapter. See paragraphs 4-1-1 and 4-1-2 at the link
> below:
>
> http://www.faa.gov/atpubs/ATC/Chp4/atc0401.html

Uh, you are referencing procedures for issuing a direct clearance to a
navaid, what I quoted was for the ever popular direct-to-an-airport
clearance, if I am understanding things right. It shows up again as
Note 1 in paragraph 4-1-2.

Sam Spade
May 7th 06, 07:56 AM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:J4F6g.175209$bm6.131782@fed1read04...
>
>>My caution applies primarily in the Western DMA. You are home free in the
>>middle of the country above 4,000, or so, and 8,000, or so in the Eastern
>>DMA. In the Western DMA there are airways a whole lot lower than areas
>>between them.
>>
>
>
> An MIA applies to the areas between them.
>
>
>
And, we hope it is applied.

Sam Spade
May 7th 06, 08:02 AM
Steven P. McNicoll wrote:


>
>
> Actually, I did answer your question, twice. You're just too dim to realize
> it.
>
> You wrote, some time ago now; "The 'rule' is that direct routes initiated by
> ATC are limited to the service volume of VOR (or rarely, NDBs) and the
> controller can assure that
> MIAs will not be violated." The "rule" has nothing to do with service
> volumes. NAVAID usable distance limits in FAAO 7110.65 are based on MSL
> altitudes and flight levels, service volumes are based on AGL altitudes.
>
> Is the bulb any brighter now?
>
>
No, I need more help to understand how VOR or NDB direct-route
assignments by ATC are based on AGL altitudes.

Sam Spade
May 7th 06, 08:05 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:MpR6g.175231$bm6.132922@fed1read04...
>
>>Part 95, IFR Altitudes establishes MEAs and is the authority for airways
>>and Jet Routes. Those airways are rules, just like an instrument approach
>>procedure is a rule.
>>
>>With instrument approach procedures (in addition to RNAV/GPS IAPs) you
>>have VOR and NBD IAPs that are approved for overlay flight with GPS. That
>>is the authorization to substitute GPS for VOR, where authorized on the
>>chart.
>>
>>You don't have any overlay (i.e., standalone, non-radar) authorization fo
>>Victor Airways or Jet Routes. Thus, if you are not in a radar environment
>>you cannot use RNAV as primary for Victor airways or Jet Routes.
>>
>>Does anyone care? Only if something goes wrong.
>>
>>There are a few Q Routes, which are predicated solely on RNAV, but thus
>>far they have been established where traffic volumne is high and radar is
>>available. They are pretty much for the airlines in the lower 48, thus
>>far. And, I believe they are all in the high altitude stratum.
>>
>>As I said before, Alaska has a special authorization that specifically
>>permits GPS/RNAV overlay of Victor airways.
>>
>
>
> You haven't cited a rule.
>
>
>
I cited Part 95. It is a rule.

Sam Spade
May 7th 06, 08:06 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:2Xx6g.175203$bm6.65816@fed1read04...
>
>>You are not allowed to use an IFR-certified GPS for en route (domestic
>>airspace) in a non-radar environment except with the special Alaska
>>provisions.
>>
>
>
> Nonsense.
>
>
Where is your reference that GPS is primary for sole means en route
navigation?

Sam Spade
May 7th 06, 08:07 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:iZx6g.175204$bm6.170325@fed1read04...
>
>>A legal interp has the full force and effect of regulation.
>>
>
>
> It does not.
>
>
It does so.

May 7th 06, 08:54 AM
Dane Spearing wrote:
> ii) VFR and hand-held GPS systems are not authorized for IFR
> navigation, for instrument approaches, or as a principle
> instrument flight references. During IFR operations, they
> may be considered only an aid to situational awareness.

Hmm. I couldn't stand reading through the whole Advisory Circular, but
as far as I can tell, the paragraph I above is the opinion of whomever
wrote the written test prep. AC 20-130A seems to only give
requirements for obtaining IFR approval for a panel mount system and
give criteria for when the "VFR Only" sticker must be applied. But
does it even say what "VFR Only" means operationally? It doesn't
mention handheld GPS at all (AFAIK).

Steven P. McNicoll
May 7th 06, 12:47 PM
"Bob Noel" > wrote in message
...
> In article >,
> "Steven P. McNicoll" > wrote:
>
>> >
>> > And how many AC's are referenced in the FARs?
>> >
>>
>> I don't know. You'll have to count them yourself.
>>
>
> can you find even one?
>


Certainly.


PART 21-CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

§ 21.305 Approval of materials, parts, processes, and appliances.
Whenever a material, part, process, or appliance is required to be approved
under this chapter, it may be approved-

(a) Under a Parts Manufacturer Approval issued under §21.303;

(b) Under a Technical Standard Order issued by the Administrator. Advisory
Circular 20-110 contains a list of Technical Standard Orders that may be
used to obtain approval. Copies of the Advisory Circular may be obtained
from the U.S. Department of Transportation, Publication Section (M-443.1),
Washington, D.C. 20590;

(c) In conjunction with type certification procedures for a product; or

(d) In any other manner approved by the Administrator.

[Amdt. 21-38, 37 FR 10659, May 26, 1972, as amended by Amdt. 21-50, 45 FR
38346, June 9, 1980]

Steven P. McNicoll
May 7th 06, 12:50 PM
"Sam Spade" > wrote in message
news:CYg7g.175496$bm6.80336@fed1read04...
>
> No, I need more help to understand how VOR or NDB direct-route assignments
> by ATC are based on AGL altitudes.
>

They aren't. It was you that said they were. That's one of the reasons
your statement was incorrect.

Steven P. McNicoll
May 7th 06, 12:51 PM
"Sam Spade" > wrote in message
news:D_g7g.175497$bm6.167703@fed1read04...
>
> I cited Part 95. It is a rule.
>

Part 95 has many rules in it. Cite the specific rule.

Steven P. McNicoll
May 7th 06, 12:53 PM
"Sam Spade" > wrote in message
news:z%g7g.175498$bm6.169019@fed1read04...
>
> Where is your reference that GPS is primary for sole means en route
> navigation?
>

I don't need one. The burden of proof is on those that claim it's use is
prohibited. It's up to them to cite the FAR that prohibits such use.

Steven P. McNicoll
May 7th 06, 12:54 PM
"Sam Spade" > wrote in message
news:G0h7g.175499$bm6.83888@fed1read04...
> Steven P. McNicoll wrote:
>
>> "Sam Spade" > wrote in message
>> news:iZx6g.175204$bm6.170325@fed1read04...
>>
>>>
>>> A legal interp has the full force and effect of regulation.
>>>
>>
>> It does not.
>
> It does so.
>

Prove it.

Steven P. McNicoll
May 7th 06, 02:18 PM
"Dane Spearing" > wrote in message
...
>
> So, the initial purpose of this thread was to discuss whether or not one
> could use a handheld GPS for IFR navigation. Lots of people have been
> tossing around lots of opinions with little or no references to rules or
> guidance to back them up (hardly surprising...this is usenet after all...)
>
> Anyway, for my own personal edification and enlightenment, I went and
> tracked down the official FAA Advisory Circular that specifies what
> the requirements are for the use of GPS under IFR. It's entitled
> "Airworthiness Approval of Navigation or Flight Management Systems
> Integrating Multiple Navigation Sensors", and is FAA AC 20-130A.
> It's about as exciting to read as the dictionary (again, hardly
> surprising). However, the Gleim Instrument Pilot Flight Manueuvers and
> Practical Test Prep guide (which is where I found the reference in the
> first place) does a nice job of summarizing the requirements for use of
> GPS under IFR as specified in AC 20-130A. It states:
>
> Authorization to conduct any GPS operation under IFR requires that:
> a) GPS navigation equipment used must be FAA-approved and the installation
> must be done in accordance with FAA requirements
> i) Approval for the use of the GPS for IFR operations, and any
> limitations, will be found in the airplane's POH (also called
> the FAA-approved Airplane Flight Manual) and the airplane's
> logbook
> ii) VFR and hand-held GPS systems are not authorized for IFR
> navigation, for instrument approaches, or as a principle
> instrument flight references. During IFR operations, they
> may be considered only an aid to situational awareness.
>
> Aircraft using GPS navigation equipment under IFR must be equipped with an
> approved and operational alternate means of navigation appropriate to the
> flight.
> a) Active monitoring of the alternative navigation equipment is not
> required
> if the GPS receiver uses RAIM for integrity monitoring.
> b) Active monitoring of the alternative navigation equipment is required
> when the RAIM capability of the GPS equipment is lost.
>
> This seems fairly clear to me.....
>

Did you read the first paragraph of AC 20-130A? The third sentence is most
revealing:


1. PURPOSE. This advisory circular (AC) establishes an acceptable means, but
not the only means, of obtaining airworthiness approval of multi-sensor
navigation or flight management systems (hereafter referred to as
multi-sensor equipment) integrating data from multiple navigation sensors
for use as a navigation system for oceanic and remote, domestic en route,
terminal, and non-precision instrument approach [except localizer, localizer
directional aid (LDA) and simplified directional facility (SDF)] operations.
This document does not address systems incorporating differential GPS
capability. Like all advisory material, this AC is not mandatory and does
not constitute a requirement. As such, the terms "shall" and "must" used in
this AC pertain to an applicant who chooses to follow the method presented.
The criteria of AC 90-45A, Approval of Area Navigation Systems for Use in
the U.S. National Airspace System, does not apply to certification of
equipment described in this AC. This AC supersedes previous GPS installation
guidance contained in: FAA Notice 8110.48, Airworthiness Approval of
Navigation or Flight Management Systems Integrating Multiple Navigation
Sensors, and FAA Interim Guidance Memoranda dated February 25, 1991; April
5, 1991; March 20, 1992; July 20, 1992; and September 21, 1993. The
appropriate information contained in those documents is incorporated in this
AC.



Here's another little gem from the Advisory Circular Checklist, AC No.
00-2.15:


3. Explanation of the AC system. The FAA issues advisory circulars to inform
the aviation public in a systematic way of non-regulatory material. Unless
incorporated into a regulation by reference, the contents of an advisory
circular are not binding on the public. Advisory circulars are issued in a
numbered-subject system corresponding to the subject areas of the Federal
Aviation Regulations (FAR) (Title 14, Code of Federal Regulations, Chapter
I, Federal Aviation Administration); and Chapter III, Commercial Space
Transportation, Federal Aviation Administration, Department of
Transportation, Parts 400-450. An AC is issued to provide guidance and
information in a designated subject area or to show a method acceptable to
the Administrator for complying with a related Federal Aviation Regulation.

Sam Spade
May 7th 06, 02:27 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:CYg7g.175496$bm6.80336@fed1read04...
>
>>No, I need more help to understand how VOR or NDB direct-route assignments
>>by ATC are based on AGL altitudes.
>>
>
>
> They aren't. It was you that said they were. That's one of the reasons
> your statement was incorrect.
>
>
You're so full of **** and deception, Steve. Here is my original post:

> The "rule" is that direct routes initiated by ATC are limited to the
> service volume of VOR (or rarely, NDBs) and the controller can assure
> that MIAs will not be violated.

You're the one that introduced "AGL altitudes."

Do you have clue about the term "intellectual honesty?"

Sam Spade
May 7th 06, 02:32 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:z%g7g.175498$bm6.169019@fed1read04...
>
>>Where is your reference that GPS is primary for sole means en route
>>navigation?
>>
>
>
> I don't need one. The burden of proof is on those that claim it's use is
> prohibited. It's up to them to cite the FAR that prohibits such use.
>
>
That is a giant load of crap.

Steven P. McNicoll
May 7th 06, 02:38 PM
> wrote in message
oups.com...
>
> Uh, you are referencing procedures for issuing a direct clearance to a
> navaid, what I quoted was for the ever popular direct-to-an-airport
> clearance, if I am understanding things right. It shows up again as
> Note 1 in paragraph 4-1-2.
>

I'm referencing the requirements for specifying a route other than an
established airway or route and the exceptions to them.

Sam Spade
May 7th 06, 02:39 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:G0h7g.175499$bm6.83888@fed1read04...
>
>>Steven P. McNicoll wrote:
>>
>>
>>>"Sam Spade" > wrote in message
>>>news:iZx6g.175204$bm6.170325@fed1read04...
>>>
>>>
>>>>A legal interp has the full force and effect of regulation.
>>>>
>>>
>>>It does not.
>>
>>It does so.
>>
>
>
> Prove it.
>
>
Apparently you have never read any FAA letters of legal interpretation.

I suggest you schedule a meeting about it with your friendly local FSDO.
Obviously, your aviation education is lacking.

Steven P. McNicoll
May 7th 06, 02:39 PM
"Sam Spade" > wrote in message
news:XSg7g.175495$bm6.14199@fed1read04...
>
> And, we hope it is applied.
>

Application is not optional.

Steven P. McNicoll
May 7th 06, 02:50 PM
"Sam Spade" > wrote in message
news:9Bm7g.175501$bm6.60501@fed1read04...
>
> You're so full of **** and deception, Steve. Here is my original post:
>
> > The "rule" is that direct routes initiated by ATC are limited to the
> > service volume of VOR (or rarely, NDBs) and the controller can assure
> > that MIAs will not be violated.
>
> You're the one that introduced "AGL altitudes."
>
> Do you have clue about the term "intellectual honesty?"
>

I sure do. Do you have a clue about the term "service volume"? I suggest
you review AIM paragraph 1-1-8 and figures 1-1-1 through 1-1-5 and then tell
me if the various altitudes given for the service volumes are AGL or MSL.

Failure to respond will be perceived as a lack of intellectual honesty.

Steven P. McNicoll
May 7th 06, 02:51 PM
"Sam Spade" > wrote in message
news:5Gm7g.175502$bm6.155268@fed1read04...
>
> That is a giant load of crap.
>

How so? Is it your position that everything is illegal until a law is
enacted making some activity legal?

Sam Spade
May 7th 06, 02:51 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:D_g7g.175497$bm6.167703@fed1read04...
>
>>I cited Part 95. It is a rule.
>>
>
>
> Part 95 has many rules in it. Cite the specific rule.
>
>
The rule:

"Subpart C - Enroute IFR Altitudes Over Particular Routes and Intersections

Editorial Note: The prescribed IFR altitudes for flights over
particular routes and intersections in this subpart were formerly
carried as sections 610.11 through 610.6887 of this title and were
transferred to Part 95 as §§ 95.41 through 95.6887, respectively, but
are not carried in the Code of Federal Regulations. For Federal Register
citations affecting these routes, see the List of CFR Sections Affected
in the Finding Aids section of this volume.
§ 95.31 General.
This subpart prescribes IFR altitudes for flights along particular
routes or route segments and over additional intersections not listed as
a part of a route or route segment."

[Doc. No. 1580, Amdt. 1-1, 28 FR 6719, June 29, 1963]"

And, from the AIM:

"a) Except in Alaska and coastal North Carolina, the VOR airways are
predicated solely on VOR or VORTAC navigation aids; are depicted in blue
on aeronautical charts; and are identified by a “V” (Victor) followed by
the airway number (e.g., V12)."

Like Part 97, Part 95 incorporates by rule-making reference individual
procedures, in this case Victor airways. The docket amending Part 95
for an individual airway is contained on Form 8260-16, and has the full
force and effect of regulation:

From 8260.19C, Flight Procedures and Airspace:

880. PREPARATION OF FAA FORM 8260-16. This form serves as a transmittal
sheet of en route procedural data to be published under 14 CFR Part 95.
It records current en route information. All airway/route
changes/cancellations must be documented on Form 8260-16 to ensure
publication. Document only one airway per Form 8260-16. If airways
overlap, document each on a separate form.
a. AIRWAY NO. OR ROUTE. Enter the airway number, "Part 95 Direct," or
"Off-Airway Non-95" as appropriate. Use a separate form for each type of
route.
Examples:
For RNAV routes - Q502
For Jet routes - J345
For Victor Airways - V123
b. FROM/TO. Each segment (fix to fix) must be listed, unless succeeding
segments have no significant changes. Segments must be separated at
facilities, flagged fixes, and changes of MEA, MOCA, or MAA. All airways
and routes terminate at the U.S. control area boundary (route alignment
may be explained in REMARKS).
(1) Route segments are normally listed from West to East for even
numbered airways, or South to North for odd numbered airways. When
amending published routes, follow the order of listing in the semiannual
consolidation of 14 CFR Part 95 routes.
(2) Fixes are identified by name, state, and type.
c. ROUTINE OR DOCKET NO. Enter the docket number when the request is
associated with an airspace action. If processing is to be routine,
leave blank.
d. CONTROLLING TERRAIN / OBSTRUCTION AND COORDINATES. When controlled
air space is a factor in MEA determination, make two entries: the
highest terrain and the highest tree or man-made obstacle (if above the
highest terrain). Use the " @ " to identify which obstacle controls the
MEA, even though MRA may require a higher altitude. Show coordinates to
the minute (seconds optional). Annotate a controlling obstacle that is
in the secondary area, and show the required obstacle clearance. No
entry is required for high altitude (Jet or RNAV) routes if terrain is
not a factor. Enter reduction of mountainous obstacle clearance.
e. MRA/MOCA. Enter both figures. To reduce chart clutter, MOCAs less
than 500 feet below MEAs should not be published unless they allow use
of a cardinal altitude within 25 SM of a facility. If a MOCA is not to
be published, line it out (the figure will still be legible for office
record purposes).
f. MAA/MEA. Enter both figures. When dual MEAs are used, show the
directions of flight. When an MEA change occurs at a DME-only fix, dual
MEAs are required since non-DME aircraft cannot receive the fix. When
minor MEA differences exist in adjacent segments, coordinate with ATC to
establish a common altitude.
g. GNSS MEA. Do not establish a GNSS MEA unless it is at least 500'
lower than the conventional MEA. The GNSS MEA must be a cardinal
altitude at or above the MOCA and provide communication capability as
required in TERPS.
NOTE:
These MEAs will be depicted on En route charts with a "G" suffix.
Example: 3500G
h. CHANGEOVER POINT. Enter the changeover point in the segment where it
lies. If midpoint, leave blank. If NOT midpoint, enter the mileage from
and the identifier of the nearest facility. If a gap exists, the
changeover point may be at the middle of the gap; however, leave blank.
If a dogleg, enter "DL." If the dogleg point is a fix, enter the fix
name. Establish a named fix on all dogleg airways that meet en route VHF
intersection criteria. Establish a named DME fix or CNF on all dogleg
airways that do not meet VHF intersection criteria.
i. FIX MRA/MCA. Entries here are referred to the appropriate fix by an
attention symbol (*). The same information is required on the Form
8260-2 for the fix. Show the direction of flight for MCAs.
j. REMARKS. Use this section for all pertinent supporting data. Typical
entries include:
Airspace floor
Terrain clearance applied
Dogleg radials for Part 95 Direct and Off-Airway
Non-95 Routes
Reason for MEA adjustment
Reason for MAA reduction
MEA gap
Cancel segment (reason)
(1) To assist charting agencies, when segments are amended or canceled,
describe the changes in this section or elsewhere on the form as
appropriate.
k. FLIGHT INSPECTION DATES. Enter the date of the original flight
inspection, if available, or indicate "On File." Use "Pending" for
new/relocated facility dockets. If flight inspection records are not
available, leave blank. Use additional lines to log subsequent flight
inspections, periodic reviews, and amendments. When the form's available
spaces are filled, whiteout the entries on manually completed forms, and
start over. Regenerate electronic forms as necessary when available
spaces are filled, deleting previously entered dates. Carry forward any
manually entered dates.
l. DISTRIBUTION. The approved Form 8260-16 must be prepared by AVN-100
and distributed as defined in Table 8-1.
m. Examples: Figure 8-3 contains a consolidated group of examples that
can be used when completing Form 8260-16.

Steven P. McNicoll
May 7th 06, 02:57 PM
"Sam Spade" > wrote in message
news:aMm7g.175503$bm6.161637@fed1read04...
>
> Apparently you have never read any FAA letters of legal interpretation.
>

I've read a few. Some of them were even logical and correct.


>
> I suggest you schedule a meeting about it with your friendly local FSDO.
> Obviously, your aviation education is lacking.
>

I've found FSDOs to be a poor source of information.

Sam Spade
May 7th 06, 02:58 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:9Bm7g.175501$bm6.60501@fed1read04...
>
>>You're so full of **** and deception, Steve. Here is my original post:
>>
>>
>>>The "rule" is that direct routes initiated by ATC are limited to the
>>>service volume of VOR (or rarely, NDBs) and the controller can assure
>>>that MIAs will not be violated.
>>
>>You're the one that introduced "AGL altitudes."
>>
>>Do you have clue about the term "intellectual honesty?"
>>
>
>
> I sure do. Do you have a clue about the term "service volume"? I suggest
> you review AIM paragraph 1-1-8 and figures 1-1-1 through 1-1-5 and then tell
> me if the various altitudes given for the service volumes are AGL or MSL.
>
> Failure to respond will be perceived as a lack of intellectual honesty.
>
>
Irrelevant. Table 4-1-1 in 7110.65 is predicated on MSL altitudes, and
that is what ATC uses.

Route procedure design (read AVN, not ATO) indeed uses service volumne
predicated on the elevation of a VOR or NDB where necessary.
Controllers do not. The context of the thread was ATC procedures for
direct routing.

Sam Spade
May 7th 06, 03:00 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:5Gm7g.175502$bm6.155268@fed1read04...
>
>>That is a giant load of crap.
>>
>
>
> How so? Is it your position that everything is illegal until a law is
> enacted making some activity legal?
>
>
No, it is not. You're right about aviation issues that are not
addressed by a body of TSOs, ACs, and ARINC documents. That absense is
the not the case with IFR equipment and operations.

Ever heard of Class I and II navigation, for instance?

Steven P. McNicoll
May 7th 06, 03:11 PM
"Sam Spade" > wrote in message
news:Y1n7g.175505$bm6.111217@fed1read04...
>
> Irrelevant. Table 4-1-1 in 7110.65 is predicated on MSL altitudes, and
> that is what ATC uses.
>

Yes, but you said ATC used service volumes, which are predicated on AGL
altitudes. Do you understand the difference between AGL and MSL? Do you
have any aviation experience at all?


>
> Route procedure design (read AVN, not ATO) indeed uses service volumne
> predicated on the elevation of a VOR or NDB where necessary. Controllers
> do not. The context of the thread was ATC procedures for direct routing.
>

Yes, that's why your statement was wrong. I'm glad you managed to learn
something in this exchange.

Newps
May 7th 06, 03:14 PM
Dane Spearing wrote:


> Authorization to conduct any GPS operation under IFR requires that:
> a) GPS navigation equipment used must be FAA-approved and the installation
> must be done in accordance with FAA requirements
> i) Approval for the use of the GPS for IFR operations, and any
> limitations, will be found in the airplane's POH (also called
> the FAA-approved Airplane Flight Manual) and the airplane's
> logbook
> ii) VFR and hand-held GPS systems are not authorized for IFR
> navigation, for instrument approaches, or as a principle
> instrument flight references. During IFR operations, they
> may be considered only an aid to situational awareness.

>
> This seems fairly clear to me.....


Shh...don't let the facts get in the way of ones mindset.

Newps
May 7th 06, 03:14 PM
Sam Spade wrote:


>>
> No, I need more help to understand how VOR or NDB direct-route
> assignments by ATC are based on AGL altitudes.

They're not, that's a ridiculous assertion.

Steven P. McNicoll
May 7th 06, 03:15 PM
"Sam Spade" > wrote in message
news:a4n7g.175506$bm6.24571@fed1read04...
>
> No, it is not.
>

Then you'll have to explain why it's a giant load of crap.


>
> You're right about aviation issues that are not addressed by a body of
> TSOs, ACs, and ARINC documents. That absense is the not the case with IFR
> equipment and operations.
>

It's not the case with IFR equipment and operations that are required to
conform with a TSO or an AC by an FAR. It is the case with IFR equipment
and operations that are not.

Steven P. McNicoll
May 7th 06, 03:17 PM
"Newps" > wrote in message
...
>
>
> Sam Spade wrote:
>
>
>>
>> No, I need more help to understand how VOR or NDB direct-route
>> assignments by ATC are based on AGL altitudes.
>>
>
> They're not, that's a ridiculous assertion.
>

Yes it is, but it was his assertion. Even if he didn't know he was
asserting it at the time.

Steven P. McNicoll
May 7th 06, 04:05 PM
"Sam Spade" > wrote in message
news:TXm7g.175504$bm6.642@fed1read04...
>
> The rule:
>
> "Subpart C - Enroute IFR Altitudes Over Particular Routes and
> Intersections
>
> Editorial Note: The prescribed IFR altitudes for flights over particular
> routes and intersections in this subpart were formerly carried as sections
> 610.11 through 610.6887 of this title and were transferred to Part 95 as
> §§ 95.41 through 95.6887, respectively, but are not carried in the Code of
> Federal Regulations. For Federal Register citations affecting these
> routes, see the List of CFR Sections Affected in the Finding Aids section
> of this volume.
> § 95.31 General.
> This subpart prescribes IFR altitudes for flights along particular routes
> or route segments and over additional intersections not listed as a part
> of a route or route segment."
>
> [Doc. No. 1580, Amdt. 1-1, 28 FR 6719, June 29, 1963]"
>

I see nothing there that addresses use of an IFR-certified GPS for en route
(domestic
airspace) in a non-radar environment nor anything about any special Alaska
provisions. FAR 95.1 says part 95 "prescribes altitudes governing the
operation of aircraft under IFR on ATS routes, or other direct routes for
which an MEA is designated in this part." We're atlking about direct
routes, those are routes for which an MEA is not designated.


>
> And, from the AIM:
>
> "a) Except in Alaska and coastal North Carolina, the VOR airways are
> predicated solely on VOR or VORTAC navigation aids; are depicted in blue
> on aeronautical charts; and are identified by a “V” (Victor) followed by
> the airway number (e.g., V12)."
>

The AIM is not regulatory.

Sam Spade
May 7th 06, 05:30 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:aMm7g.175503$bm6.161637@fed1read04...
>
>>Apparently you have never read any FAA letters of legal interpretation.
>>
>
>
> I've read a few. Some of them were even logical and correct.
>
>
>
>>I suggest you schedule a meeting about it with your friendly local FSDO.
>>Obviously, your aviation education is lacking.
>>
>
>
> I've found FSDOs to be a poor source of information.
>
>
As they probably find you to be a bit closed-mind.

Sam Spade
May 7th 06, 05:32 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:TXm7g.175504$bm6.642@fed1read04...
>
>>The rule:
>>
>>"Subpart C - Enroute IFR Altitudes Over Particular Routes and
>>Intersections
>>
>>Editorial Note: The prescribed IFR altitudes for flights over particular
>>routes and intersections in this subpart were formerly carried as sections
>>610.11 through 610.6887 of this title and were transferred to Part 95 as
>>§§ 95.41 through 95.6887, respectively, but are not carried in the Code of
>>Federal Regulations. For Federal Register citations affecting these
>>routes, see the List of CFR Sections Affected in the Finding Aids section
>>of this volume.
>>§ 95.31 General.
>>This subpart prescribes IFR altitudes for flights along particular routes
>>or route segments and over additional intersections not listed as a part
>>of a route or route segment."
>>
>>[Doc. No. 1580, Amdt. 1-1, 28 FR 6719, June 29, 1963]"
>>
>
>
> I see nothing there that addresses use of an IFR-certified GPS for en route
> (domestic
> airspace) in a non-radar environment nor anything about any special Alaska
> provisions. FAR 95.1 says part 95 "prescribes altitudes governing the
> operation of aircraft under IFR on ATS routes, or other direct routes for
> which an MEA is designated in this part." We're atlking about direct
> routes, those are routes for which an MEA is not designated.
>
>
>
>>And, from the AIM:
>>
>>"a) Except in Alaska and coastal North Carolina, the VOR airways are
>>predicated solely on VOR or VORTAC navigation aids; are depicted in blue
>>on aeronautical charts; and are identified by a “V” (Victor) followed by
>>the airway number (e.g., V12)."
>>
>
>
> The AIM is not regulatory.
>
>
You are either stupid or stubborn, or perhaps both. The AIM reference
is explanatory. The 8260-16, when describing Federal Airwaty V-XXX,
which is formed by VOR facilities, is regulatory.

It's all there, for the non-selective reader.

Sam Spade
May 7th 06, 05:33 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:Y1n7g.175505$bm6.111217@fed1read04...
>
>>Irrelevant. Table 4-1-1 in 7110.65 is predicated on MSL altitudes, and
>>that is what ATC uses.
>>
>
>
> Yes, but you said ATC used service volumes, which are predicated on AGL
> altitudes. Do you understand the difference between AGL and MSL? Do you
> have any aviation experience at all?
>
>
>
>>Route procedure design (read AVN, not ATO) indeed uses service volumne
>>predicated on the elevation of a VOR or NDB where necessary. Controllers
>>do not. The context of the thread was ATC procedures for direct routing.
>>
>
>
> Yes, that's why your statement was wrong. I'm glad you managed to learn
> something in this exchange.
>
>
Not so. You just can't read with any objectivity.

Sam Spade
May 7th 06, 05:34 PM
Steven P. McNicoll wrote:

> "Newps" > wrote in message
> ...
>
>>
>>Sam Spade wrote:
>>
>>
>>
>>>No, I need more help to understand how VOR or NDB direct-route
>>>assignments by ATC are based on AGL altitudes.
>>>
>>
>>They're not, that's a ridiculous assertion.
>>
>
>
> Yes it is, but it was his assertion. Even if he didn't know he was
> asserting it at the time.
>
>
That is pure bull****. You brought up AGL, not me. I was referring to
7110.65, not the AIM.

Sam Spade
May 7th 06, 05:34 PM
Newps wrote:

>
>
> Sam Spade wrote:
>
>
>>>
>> No, I need more help to understand how VOR or NDB direct-route
>> assignments by ATC are based on AGL altitudes.
>
>
> They're not, that's a ridiculous assertion.
>
And, it's Stevie's assertion.

Steven P. McNicoll
May 7th 06, 05:43 PM
"Sam Spade" > wrote in message
news:Ygp7g.175614$bm6.138484@fed1read04...
>
> As they probably find you to be a bit closed-mind.
>

You'll never find anyone more open-minded than me.

Steven P. McNicoll
May 7th 06, 05:45 PM
"Sam Spade" > wrote in message
news:Wip7g.175615$bm6.36868@fed1read04...
>
> You are either stupid or stubborn, or perhaps both.

I am neither.


>
> The AIM reference is explanatory.

The AIM is not regulatory.


>
> The 8260-16, when describing Federal Airwaty V-XXX, which is formed by VOR
> facilities, is regulatory.
>

Irrelevant to the subject under discussion.

Steven P. McNicoll
May 7th 06, 05:46 PM
"Sam Spade" > wrote in message
news:Cjp7g.175616$bm6.42955@fed1read04...
>
> Not so. You just can't read with any objectivity.
>

Are service volumes based on AGL or MSL altitudes?

Steven P. McNicoll
May 7th 06, 05:47 PM
"Sam Spade" > wrote in message
news:pkp7g.175617$bm6.114407@fed1read04...
>
> That is pure bull****. You brought up AGL, not me. I was referring to
> 7110.65, not the AIM.
>

You brought up service volumes. Are service volumes based on AGL or MSL
altitudes?

Steven P. McNicoll
May 7th 06, 05:48 PM
"Sam Spade" > wrote in message
news:Pkp7g.175618$bm6.124940@fed1read04...
>
> And, it's Stevie's assertion.
>

Please provide a quote of Stevie asserting that.

Ted
May 7th 06, 06:46 PM
"Steven P. McNicoll" > wrote in message
k.net...
>
> "Dane Spearing" > wrote in message
> ...
>>
>> So, the initial purpose of this thread was to discuss whether or not one
>> could use a handheld GPS for IFR navigation. Lots of people have been
>> tossing around lots of opinions with little or no references to rules or
>> guidance to back them up (hardly surprising...this is usenet after
>> all...)
>>
>> Anyway, for my own personal edification and enlightenment, I went and
>> tracked down the official FAA Advisory Circular that specifies what
>> the requirements are for the use of GPS under IFR. It's entitled
>> "Airworthiness Approval of Navigation or Flight Management Systems
>> Integrating Multiple Navigation Sensors", and is FAA AC 20-130A.
>> It's about as exciting to read as the dictionary (again, hardly
>> surprising). However, the Gleim Instrument Pilot Flight Manueuvers and
>> Practical Test Prep guide (which is where I found the reference in the
>> first place) does a nice job of summarizing the requirements for use of
>> GPS under IFR as specified in AC 20-130A. It states:
>>
>> Authorization to conduct any GPS operation under IFR requires that:
>> a) GPS navigation equipment used must be FAA-approved and the
>> installation
>> must be done in accordance with FAA requirements
>> i) Approval for the use of the GPS for IFR operations, and any
>> limitations, will be found in the airplane's POH (also called
>> the FAA-approved Airplane Flight Manual) and the airplane's
>> logbook
>> ii) VFR and hand-held GPS systems are not authorized for IFR
>> navigation, for instrument approaches, or as a principle
>> instrument flight references. During IFR operations, they
>> may be considered only an aid to situational awareness.
>>
>> Aircraft using GPS navigation equipment under IFR must be equipped with
>> an
>> approved and operational alternate means of navigation appropriate to the
>> flight.
>> a) Active monitoring of the alternative navigation equipment is not
>> required
>> if the GPS receiver uses RAIM for integrity monitoring.
>> b) Active monitoring of the alternative navigation equipment is required
>> when the RAIM capability of the GPS equipment is lost.
>>
>> This seems fairly clear to me.....
>>
>
> Did you read the first paragraph of AC 20-130A? The third sentence is
> most
> revealing:
>
>
> 1. PURPOSE. This advisory circular (AC) establishes an acceptable means,
> but
> not the only means, of obtaining airworthiness approval of multi-sensor
> navigation or flight management systems (hereafter referred to as
> multi-sensor equipment) integrating data from multiple navigation sensors
> for use as a navigation system for oceanic and remote, domestic en route,
> terminal, and non-precision instrument approach [except localizer,
> localizer
> directional aid (LDA) and simplified directional facility (SDF)]
> operations.
> This document does not address systems incorporating differential GPS
> capability. Like all advisory material, this AC is not mandatory and does
> not constitute a requirement. As such, the terms "shall" and "must" used
> in
> this AC pertain to an applicant who chooses to follow the method
> presented.
> The criteria of AC 90-45A, Approval of Area Navigation Systems for Use in
> the U.S. National Airspace System, does not apply to certification of
> equipment described in this AC. This AC supersedes previous GPS
> installation
> guidance contained in: FAA Notice 8110.48, Airworthiness Approval of
> Navigation or Flight Management Systems Integrating Multiple Navigation
> Sensors, and FAA Interim Guidance Memoranda dated February 25, 1991; April
> 5, 1991; March 20, 1992; July 20, 1992; and September 21, 1993. The
> appropriate information contained in those documents is incorporated in
> this
> AC.
>
>
>
> Here's another little gem from the Advisory Circular Checklist, AC No.
> 00-2.15:
>
>
> 3. Explanation of the AC system. The FAA issues advisory circulars to
> inform
> the aviation public in a systematic way of non-regulatory material. Unless
> incorporated into a regulation by reference, the contents of an advisory
> circular are not binding on the public. Advisory circulars are issued in a
> numbered-subject system corresponding to the subject areas of the Federal
> Aviation Regulations (FAR) (Title 14, Code of Federal Regulations, Chapter
> I, Federal Aviation Administration); and Chapter III, Commercial Space
> Transportation, Federal Aviation Administration, Department of
> Transportation, Parts 400-450. An AC is issued to provide guidance and
> information in a designated subject area or to show a method acceptable to
> the Administrator for complying with a related Federal Aviation
> Regulation.
>

Its amazing the things one can learn if one actually knows how to read.

Perhaps a reading and writing test should be part of the basic pilot's
license?

Ted
May 7th 06, 06:50 PM
"Sam Spade" > wrote in message
news:5Gm7g.175502$bm6.155268@fed1read04...
> Steven P. McNicoll wrote:
>
>> "Sam Spade" > wrote in message
>> news:z%g7g.175498$bm6.169019@fed1read04...
>>
>>>Where is your reference that GPS is primary for sole means en route
>>>navigation?
>>>
>>
>>
>> I don't need one. The burden of proof is on those that claim it's use is
>> prohibited. It's up to them to cite the FAR that prohibits such use.
> That is a giant load of crap.

It seems like a basic tenet of the law to me. Where did you learn how to
follow rules that don't exist?

Ted
May 7th 06, 06:54 PM
"Steven P. McNicoll" > wrote in message
k.net...
>
> "Sam Spade" > wrote in message
> news:5Gm7g.175502$bm6.155268@fed1read04...
>>
>> That is a giant load of crap.
>>
>
> How so? Is it your position that everything is illegal until a law is
> enacted making some activity legal?
>

I've seen this leap of illogic before. It us usually uttered by a desperate
man who finds himself argued into a corner and is beginning to realize that
his own prejudices, opinions, feelings and beliefs do not have the force of
law.

Next you might hear him try to claim that it has the force of law because
"that's the way we have always done it".

Steven P. McNicoll
May 7th 06, 06:56 PM
"Ted" > wrote in message
ink.net...
>
> Its amazing the things one can learn if one actually knows how to read.
>
> Perhaps a reading and writing test should be part of the basic pilot's
> license?
>

Perhaps. Being able to read, speak, write, and understand the English
language is a requirement, apparently it's just assumed that applicants meet
it.

Ted
May 7th 06, 07:07 PM
"Sam Spade" > wrote in message
news:Pkp7g.175618$bm6.124940@fed1read04...

> And, it's Stevie's assertion.

>...That is pure bull****....

> ...You are either stupid or stubborn...

Sam, does your mother wash your mouth out with soap when you try and use
that language in front of her?

Are you losing your grip, Sam?

Perhaps you should take some valium and relax a bit before you attempt to
continue this legal discussion as you are clearly overwhelmed by those who
disagree with you?

Ron Lee
May 7th 06, 11:08 PM
>> Authorization to conduct any GPS operation under IFR requires that:
>> a) GPS navigation equipment used must be FAA-approved and the installation
>> must be done in accordance with FAA requirements
>> i) Approval for the use of the GPS for IFR operations, and any
>> limitations, will be found in the airplane's POH (also called
>> the FAA-approved Airplane Flight Manual) and the airplane's
>> logbook
>> ii) VFR and hand-held GPS systems are not authorized for IFR
>> navigation, for instrument approaches, or as a principle
>> instrument flight references. During IFR operations, they
>> may be considered only an aid to situational awareness.
>
>>
>> This seems fairly clear to me.....
>
>
>Shh...don't let the facts get in the way of ones mindset.

A primary reason that handheld/VFR GPS units are not acceptable for
VFR use is that they not not include an integrity capability. That is
essential for IFR ops.

Ron Lee

May 7th 06, 11:39 PM
Newps wrote:
> Dane Spearing wrote:
>
>
> > Authorization to conduct any GPS operation under IFR requires that:
> > a) GPS navigation equipment used must be FAA-approved and the installation
> > must be done in accordance with FAA requirements
> > i) Approval for the use of the GPS for IFR operations, and any
> > limitations, will be found in the airplane's POH (also called
> > the FAA-approved Airplane Flight Manual) and the airplane's
> > logbook
> > ii) VFR and hand-held GPS systems are not authorized for IFR
> > navigation, for instrument approaches, or as a principle
> > instrument flight references. During IFR operations, they
> > may be considered only an aid to situational awareness.
>
> >
> > This seems fairly clear to me.....
>
>
> Shh...don't let the facts get in the way of ones mindset.

That's not fact. As far as I can tell, the advisory circular that the
"fact" supposedly came from was paraphrased by some written test
preparation materials. That is what you quoted. Not fact. See the
original message from Dane. Neither the AC nor POHs say anything about
handhelds.

May 7th 06, 11:53 PM
Ron Lee wrote:
>
> A primary reason that handheld/VFR GPS units are not acceptable for
> VFR use is that they not not include an integrity capability. That is
> essential for IFR ops.
>
> Ron Lee

Sure, sounds good, but then if the FAA regulated by reason, NDB
approaches would have been made illegal long ago. I would bet many
more people have been injured and killed because of crappy ADFs and
just plain inaccurate old technology than by using a handheld GPS unit
while flying enroute. Even VORs don't have much for "integrity
monitoring," just that dumb little flag. I've seen many inaccurate VOR
readings and some outright failures without the flag showing red.

I've also seen handheld GPSs fail, too. But, in general, they are
probably more accurate and dependable than VOR and ADF.

Peter

Steven P. McNicoll
May 8th 06, 12:04 AM
"Ron Lee" > wrote in message
...
>
> A primary reason that handheld/VFR GPS units are not acceptable for
> VFR use is that they not not include an integrity capability. That is
> essential for IFR ops.
>

This is like a religion with you people. It's strictly a matter faith that
use of handheld GPS during IFR enroute flight in US controlled airspace is
illegal and/or unsafe.

Roy Smith
May 8th 06, 12:09 AM
In article et>,
"Steven P. McNicoll" > wrote:

> "Ron Lee" > wrote in message
> ...
> >
> > A primary reason that handheld/VFR GPS units are not acceptable for
> > VFR use is that they not not include an integrity capability. That is
> > essential for IFR ops.
> >
>
> This is like a religion with you people. It's strictly a matter faith that
> use of handheld GPS during IFR enroute flight in US controlled airspace is
> illegal and/or unsafe.

It depends on what you're using it for. A handheld GPS and a ham sandwich
are both useful objects, but using either one for the other's intended
purpose can be dangerous.

May 8th 06, 12:22 AM
Roy Smith wrote:
>
> It depends on what you're using it for. A handheld GPS and a ham sandwich
> are both useful objects, but using either one for the other's intended
> purpose can be dangerous.

Well, there are those stories of the open-cockpit airmail pilots using
cigars to time approaches. Don't know about ham sandwiches though. I
suppose if you're Steve Fossett, and your sandwich starts getting
moldy, you're about to run outa gas.

Dane Spearing
May 8th 06, 12:31 AM
In article . com>,
> wrote:
>That's not fact. As far as I can tell, the advisory circular that the
>"fact" supposedly came from was paraphrased by some written test
>preparation materials. That is what you quoted. Not fact. See the
>original message from Dane. Neither the AC nor POHs say anything about
>handhelds.

Section 1-1-19-d of the AIM addresses the general requirements
for conducting any GPS operations under IFR. Section 1-1-19-d1a
explicitly states (and I quote):

"Visual flight rules (VFR) and hand-held GPS systems are not authorized
for IFR navigation, instrument approaches, or as a principal instrument
flight reference."

It appears that the Gleim written test prep materials I cited in my previous
posting took much of their material from the AIM and not the AC. The AIM,
however, also does cite AC 20-138.

Again, this seems fairly clear to me.

-- Dane

Steven P. McNicoll
May 8th 06, 12:44 AM
"Dane Spearing" > wrote in message
...
>
> Section 1-1-19-d of the AIM addresses the general requirements
> for conducting any GPS operations under IFR. Section 1-1-19-d1a
> explicitly states (and I quote):
>
> "Visual flight rules (VFR) and hand-held GPS systems are not authorized
> for IFR navigation, instrument approaches, or as a principal instrument
> flight reference."
>
> It appears that the Gleim written test prep materials I cited in my
> previous
> posting took much of their material from the AIM and not the AC. The AIM,
> however, also does cite AC 20-138.
>
> Again, this seems fairly clear to me.
>

Faith is a mysterious thing.

Ted
May 8th 06, 02:28 AM
"Roy Smith" > wrote in message
...
> In article et>,
> "Steven P. McNicoll" > wrote:
>
>> "Ron Lee" > wrote in message
>> ...
>> >
>> > A primary reason that handheld/VFR GPS units are not acceptable for
>> > VFR use is that they not not include an integrity capability. That is
>> > essential for IFR ops.
>> >
>>
>> This is like a religion with you people. It's strictly a matter faith
>> that
>> use of handheld GPS during IFR enroute flight in US controlled airspace
>> is
>> illegal and/or unsafe.
>
> It depends on what you're using it for. A handheld GPS and a ham sandwich
> are both useful objects, but using either one for the other's intended
> purpose can be dangerous.

If not nutritious.

Ted
May 8th 06, 02:33 AM
"Steven P. McNicoll" > wrote in message
ink.net...
>
> "Dane Spearing" > wrote in message
> ...
>>
>> Section 1-1-19-d of the AIM addresses the general requirements
>> for conducting any GPS operations under IFR. Section 1-1-19-d1a
>> explicitly states (and I quote):
>>
>> "Visual flight rules (VFR) and hand-held GPS systems are not authorized
>> for IFR navigation, instrument approaches, or as a principal instrument
>> flight reference."
>>
>> It appears that the Gleim written test prep materials I cited in my
>> previous
>> posting took much of their material from the AIM and not the AC. The
>> AIM,
>> however, also does cite AC 20-138.
>>
>> Again, this seems fairly clear to me.
>>
>
> Faith is a mysterious thing.
>

Careful, Steven. If they determine that you are an infidel then they may
petition the Pope to excommunicate you.

Roy Smith
May 8th 06, 02:41 AM
In article et>,
"Ted" > wrote:

> "Roy Smith" > wrote in message
> ...
> > In article et>,
> > "Steven P. McNicoll" > wrote:
> >
> >> "Ron Lee" > wrote in message
> >> ...
> >> >
> >> > A primary reason that handheld/VFR GPS units are not acceptable for
> >> > VFR use is that they not not include an integrity capability. That is
> >> > essential for IFR ops.
> >> >
> >>
> >> This is like a religion with you people. It's strictly a matter faith
> >> that
> >> use of handheld GPS during IFR enroute flight in US controlled airspace
> >> is
> >> illegal and/or unsafe.
> >
> > It depends on what you're using it for. A handheld GPS and a ham sandwich
> > are both useful objects, but using either one for the other's intended
> > purpose can be dangerous.
>
> If not nutritious.

Most handheld GPS's that I've seen are somewhat lacking in the nutrition
department.

Frank Ch. Eigler
May 8th 06, 03:48 AM
Sam Spade > writes:

> Steven P. McNicoll wrote:
> > Yes, that's why your statement was wrong. I'm glad you managed to
> > learn something in this exchange.
>
> Not so. You just can't read with any objectivity.

McNicoll is known for picking or inventing the most immaterial nits
with of the most unreasonable interpretations of ordinary discussion.
His dedication to the task is kind of sad for onlookers and
aggravating to participants -- kind of like a three-year old asking
"why?" ad infinitum. Offer him a lollipop, not more argument.

- FChE

Steven P. McNicoll
May 8th 06, 04:03 AM
"Frank Ch. Eigler" > wrote in message
...
>
> McNicoll is known for picking or inventing the most immaterial nits
> with of the most unreasonable interpretations of ordinary discussion.
> His dedication to the task is kind of sad for onlookers and
> aggravating to participants -- kind of like a three-year old asking
> "why?" ad infinitum. Offer him a lollipop, not more argument.
>

He has yet to offer any argument.

May 8th 06, 07:43 AM
Dane Spearing wrote:

> Section 1-1-19-d of the AIM addresses the general requirements
> for conducting any GPS operations under IFR. Section 1-1-19-d1a
> explicitly states (and I quote):
>
> "Visual flight rules (VFR) and hand-held GPS systems are not authorized
> for IFR navigation, instrument approaches, or as a principal instrument
> flight reference."

Okay. Good find. Now, some will always bring up the fact that the AIM
is not regulatory, but it is an official FAA publication and therefore
cannot be disregarded. I somehow missed that sentence over the years.
So I suppose weaseling around it by claiming its really GPS-assisted
dead reckoning is necessary.

So if the AIM says that handhelds are not authorized for IFR
navigation, there must be a rule somewhere, right?

May 8th 06, 07:56 AM
Steven P. McNicoll wrote:
>
> Faith is a mysterious thing.

I suppose this means that this has come up before and you have a good
counterpoint for it? Besides throwing out the entire AIM, I hope.

Matt Whiting
May 8th 06, 10:59 AM
wrote:
> Dane Spearing wrote:
>
>
>>Section 1-1-19-d of the AIM addresses the general requirements
>>for conducting any GPS operations under IFR. Section 1-1-19-d1a
>>explicitly states (and I quote):
>>
>>"Visual flight rules (VFR) and hand-held GPS systems are not authorized
>>for IFR navigation, instrument approaches, or as a principal instrument
>>flight reference."
>
>
> Okay. Good find. Now, some will always bring up the fact that the AIM
> is not regulatory, but it is an official FAA publication and therefore
> cannot be disregarded. I somehow missed that sentence over the years.
> So I suppose weaseling around it by claiming its really GPS-assisted
> dead reckoning is necessary.
>
> So if the AIM says that handhelds are not authorized for IFR
> navigation, there must be a rule somewhere, right?

Not necessarily. The AIM is meant to contain information that is "good
practice", not just regulatory information. The FARs are for
regulation. If the AIM was also regulatory and only contained
information already in the FARs, what would be the point of it?


Matt

Travis Marlatte
May 8th 06, 12:43 PM
No, it was yours, Sam. Whether you knew it or not. Steven simply picked up
on your fairly inocent, but mistaken statement that ATC uses SERVICE VOLUMES
to guide direct routing. You even referenced a table that is NOT based on
service volumes.

You both agree about the limitations on direct routing and Steven knows it.
He just likes to nit pick the details.


--
-------------------------------
Travis
Lake N3094P
PWK


"Sam Spade" > wrote in message
news:Pkp7g.175618$bm6.124940@fed1read04...
> Newps wrote:
>
>>
>>
>> Sam Spade wrote:
>>
>>
>>>>
>>> No, I need more help to understand how VOR or NDB direct-route
>>> assignments by ATC are based on AGL altitudes.
>>
>>
>> They're not, that's a ridiculous assertion.
>>
> And, it's Stevie's assertion.

Travis Marlatte
May 8th 06, 01:02 PM
Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the
fact that Alaska has special rules does not mean anything for the other 49
states.

--
-------------------------------
Travis
Lake N3094P
PWK


"Sam Spade" > wrote in message
news:Wip7g.175615$bm6.36868@fed1read04...
> Steven P. McNicoll wrote:
>
>> "Sam Spade" > wrote in message
>> news:TXm7g.175504$bm6.642@fed1read04...
>>
>>>The rule:
>>>
>>>"Subpart C - Enroute IFR Altitudes Over Particular Routes and
>>>Intersections
>>>
>>>Editorial Note: The prescribed IFR altitudes for flights over particular
>>>routes and intersections in this subpart were formerly carried as
>>>sections 610.11 through 610.6887 of this title and were transferred to
>>>Part 95 as §§ 95.41 through 95.6887, respectively, but are not carried in
>>>the Code of Federal Regulations. For Federal Register citations affecting
>>>these routes, see the List of CFR Sections Affected in the Finding Aids
>>>section of this volume.
>>>§ 95.31 General.
>>>This subpart prescribes IFR altitudes for flights along particular routes
>>>or route segments and over additional intersections not listed as a part
>>>of a route or route segment."
>>>
>>>[Doc. No. 1580, Amdt. 1-1, 28 FR 6719, June 29, 1963]"
>>>
>>
>>
>> I see nothing there that addresses use of an IFR-certified GPS for en
>> route (domestic
>> airspace) in a non-radar environment nor anything about any special
>> Alaska
>> provisions. FAR 95.1 says part 95 "prescribes altitudes governing the
>> operation of aircraft under IFR on ATS routes, or other direct routes for
>> which an MEA is designated in this part." We're atlking about direct
>> routes, those are routes for which an MEA is not designated.
>>
>>
>>
>>>And, from the AIM:
>>>
>>>"a) Except in Alaska and coastal North Carolina, the VOR airways are
>>>predicated solely on VOR or VORTAC navigation aids; are depicted in blue
>>>on aeronautical charts; and are identified by a “V” (Victor) followed by
>>>the airway number (e.g., V12)."
>>>
>>
>>
>> The AIM is not regulatory.
> You are either stupid or stubborn, or perhaps both. The AIM reference is
> explanatory. The 8260-16, when describing Federal Airwaty V-XXX, which is
> formed by VOR facilities, is regulatory.
>
> It's all there, for the non-selective reader.

Roy Smith
May 8th 06, 01:59 PM
In article >,
Matt Whiting > wrote:

> > So if the AIM says that handhelds are not authorized for IFR
> > navigation, there must be a rule somewhere, right?
>
> Not necessarily. The AIM is meant to contain information that is "good
> practice", not just regulatory information. The FARs are for
> regulation. If the AIM was also regulatory and only contained
> information already in the FARs, what would be the point of it?

Yes, it's true that the AIM is "not regulatory". We all learned that and
regurgitated it back on some private pilot knowledge test long ago. But,
just because it doesn't cite chapter and verse from 14 CFR is no reason to
completely ignore what it says.

The paragraph in question is 1-1-19-d-1-(a):

> 1. Authorization to conduct any GPS operation under IFR requires that:
>
> (a) GPS navigation equipment used must be approved in accordance with the
> requirements specified in Technical Standard Order (TSO) TSO-C129, or
> equivalent, and the installation must be done in accordance with Advisory
> Circular AC 20-138, Airworthiness Approval of Global Positioning System (GPS)
> Navigation Equipment for Use as a VFR and IFR Supplemental Navigation System,
> or Advisory Circular AC 20-130A, Airworthiness Approval of Navigation or
> Flight Management Systems Integrating Multiple Navigation Sensors, or
> equivalent. Equipment approved in accordance with TSO-C115a does not meet the
> requirements of TSO-C129. Visual flight rules (VFR) and hand-held GPS systems
> are not authorized for IFR navigation, instrument approaches, or as a
> principal instrument flight reference. During IFR operations they may be
> considered only an aid to situational awareness.

While the AIM may not be regulatory, it also doesn't lie. When a simple
declaratory statement is made such as, "hand-held GPS systems are not
authorized for IFR navigation, instrument approaches, or as a principal
instrument flight reference", it's a pretty good guess that there is some
regulation, somewhere that backs that up. Anybody who feels confident
enough that handheld GPS is good enough for IFR is welcome to invite an
FSDO guy to ride along with you for an inspection with a handheld as your
sole means of IFR navigation outside of DR, vectors, celestial, and a ham
sandwich. See how far you get. Then please post about it so we can all
share in your experience.

Until that time, all this talk about how the AIM is not regulatory and how
it's OK to fly IFR with a handheld is just a lot of masturbation.

Steven P. McNicoll
May 8th 06, 02:56 PM
"Ron Lee" > wrote in message
...
>
> A primary reason that handheld/VFR GPS units are not acceptable for
> VFR use is that they not not include an integrity capability. That is
> essential for IFR ops.
>

Can you explain why that is so?

Sam Spade
May 8th 06, 04:20 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:Ygp7g.175614$bm6.138484@fed1read04...
>
>>As they probably find you to be a bit closed-mind.
>>
>
>
> You'll never find anyone more open-minded than me.
>
>
Thanks for helping me on that one, too!

Sam Spade
May 8th 06, 04:20 PM
Ted wrote:

> "Sam Spade" > wrote in message
> news:5Gm7g.175502$bm6.155268@fed1read04...
>
>>Steven P. McNicoll wrote:
>>
>>
>>>"Sam Spade" > wrote in message
>>>news:z%g7g.175498$bm6.169019@fed1read04...
>>>
>>>
>>>>Where is your reference that GPS is primary for sole means en route
>>>>navigation?
>>>>
>>>
>>>
>>>I don't need one. The burden of proof is on those that claim it's use is
>>>prohibited. It's up to them to cite the FAR that prohibits such use.
>>
>>That is a giant load of crap.
>
>
> It seems like a basic tenet of the law to me. Where did you learn how to
> follow rules that don't exist?
>
>
>
>
Who me? I agree with you.

Sam Spade
May 8th 06, 04:21 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:Wip7g.175615$bm6.36868@fed1read04...
>
>>You are either stupid or stubborn, or perhaps both.
>
>
> I am neither.
>
>
>
>>The AIM reference is explanatory.
>
>
> The AIM is not regulatory.
>
>
>
>>The 8260-16, when describing Federal Airwaty V-XXX, which is formed by VOR
>>facilities, is regulatory.
>>
>
>
> Irrelevant to the subject under discussion.
>
>
Bull****.

Sam Spade
May 8th 06, 04:21 PM
Travis Marlatte wrote:

> Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the
> fact that Alaska has special rules does not mean anything for the other 49
> states.
>
But Part 95 is.

Steven P. McNicoll
May 8th 06, 04:31 PM
> wrote in message
oups.com...
>
> Okay. Good find. Now, some will always bring up the fact that the AIM
> is not regulatory, but it is an official FAA publication and therefore
> cannot be disregarded. I somehow missed that sentence over the years.
> So I suppose weaseling around it by claiming its really GPS-assisted
> dead reckoning is necessary.
>
> So if the AIM says that handhelds are not authorized for IFR
> navigation, there must be a rule somewhere, right?
>

One would think so, but there isn't.

Steven P. McNicoll
May 8th 06, 04:36 PM
> wrote in message
oups.com...
>
> I suppose this means that this has come up before and you have a good
> counterpoint for it? Besides throwing out the entire AIM, I hope.
>

Oh, it's come up many times. This is like a religion with some people, a
matter of faith. They insist use of handheld GPS during IFR enroute
operations in US controlled airspace is illegal and/or unsafe but none of
them can identify any regulation that prohibits it or any hazard caused by
such use.

Steven P. McNicoll
May 8th 06, 04:47 PM
"Roy Smith" > wrote in message
...
>
> Yes, it's true that the AIM is "not regulatory". We all learned that and
> regurgitated it back on some private pilot knowledge test long ago. But,
> just because it doesn't cite chapter and verse from 14 CFR is no reason to
> completely ignore what it says.
>
> The paragraph in question is 1-1-19-d-1-(a):
>
>> 1. Authorization to conduct any GPS operation under IFR requires that:
>>
>> (a) GPS navigation equipment used must be approved in accordance with the
>> requirements specified in Technical Standard Order (TSO) TSO-C129, or
>> equivalent, and the installation must be done in accordance with Advisory
>> Circular AC 20-138, Airworthiness Approval of Global Positioning System
>> (GPS)
>> Navigation Equipment for Use as a VFR and IFR Supplemental Navigation
>> System,
>> or Advisory Circular AC 20-130A, Airworthiness Approval of Navigation or
>> Flight Management Systems Integrating Multiple Navigation Sensors, or
>> equivalent. Equipment approved in accordance with TSO-C115a does not meet
>> the
>> requirements of TSO-C129. Visual flight rules (VFR) and hand-held GPS
>> systems
>> are not authorized for IFR navigation, instrument approaches, or as a
>> principal instrument flight reference. During IFR operations they may be
>> considered only an aid to situational awareness.
>
> While the AIM may not be regulatory, it also doesn't lie. When a simple
> declaratory statement is made such as, "hand-held GPS systems are not
> authorized for IFR navigation, instrument approaches, or as a principal
> instrument flight reference", it's a pretty good guess that there is some
> regulation, somewhere that backs that up. Anybody who feels confident
> enough that handheld GPS is good enough for IFR is welcome to invite an
> FSDO guy to ride along with you for an inspection with a handheld as your
> sole means of IFR navigation outside of DR, vectors, celestial, and a ham
> sandwich. See how far you get. Then please post about it so we can all
> share in your experience.
>
> Until that time, all this talk about how the AIM is not regulatory and how
> it's OK to fly IFR with a handheld is just a lot of masturbation.
>

You don't have to make an actual flight, a hypothetical will work just as
well for this purpose. I did just that some 6 1/2 years ago. The message
below was originally posted on December 4th, 1999, in this forum in the
thread "Going direct to an intersection":





I sent the following message to eleven of the fourteen FSDOs in the Great
Lakes Region:

"I have a question regarding the use of a handheld GPS receiver
during IFR enroute flight.


Let's say I file from MBS direct to SEA in my BE36/A. My Bonanza
has two nav/coms, ADF, GS receiver, DME, marker beacon receiver,
transponder, encoder, and an autopilot. But I intend to use my
handheld GPS receiver for enroute navigation, which I have previously
determined will not cause interference with the navigation or communication
system on my airplane. ATC clears me as filed and I proceed on my merry way
direct to Seattle.


Does this operation violate any FAR?"


I received E-mail responses from four FSDOs, I have changed only
identification of offices and individuals.


From FSDO "A":


Dear Steven,


Thank you for your question concerning GPS Navigation.


You must comply with the limitations of your GPS. There isn't
a handheld alive that is approved for IFR enroute or terminal
navigation, so to answer your question, no, you cannot use the
GPS for anything during your IFR Flight. I recommend that you
review your GPS Manual provided by the factory.


I hope this answers your question, Steven.


Sincerely,


John Doe
FSDO "A"


Dear Mr. Doe,


Thank you for your prompt response.


My question and scenario are completely hypothetical, I don't own a
GPS (or a Bonanza, unfortunately), so I have no GPS manual to
review. But I'm afraid you didn't answer my question; I wanted to
know what regulation, if any, was being violated in the scenario.
What FAR prohibits the use of a handheld GPS during enroute IFR
flight? What regulation requires me to comply with the limitations
of my GPS? What regulation requires the GPS, or any other nav
system for that matter, to be approved for IFR enroute flight?


Sincerely,
Steven P. McNicoll


No further messages were received from FSDO "A".


From FSDO "B":


Dear Steven,


Does this operation violate any FAR?


FAR - "singular" NO, "pural" YES


or only if the FAA accident investigation team has to pry it out of
your cold hands at the site of the crash, otherwise no one will know.


Sorry, but I just can't pass up to opportunity to put a little humor into
my work. Seriously here is the"spin" that most FAA types put on
the answer to this question.


Hand held GPS units are not approved for flight into IFR conditions. Panel
mount GPS units may be certified for enroute portions only,
or the high dollar units that meet all the FAA's certification
requirements can be used for enroute and approaches, these units
are also panel mounted units.


Further, the panel mounted units are to be installed by properly
certificated technicians and the equipment list, weight and balance
of the aircraft should reflect the additional equipment. (No the FAA
doesn't make it easy.)


So in the case of a handheld GPS for IFR flight, the unit is not
certified for that use and is not authorized by FARs.


Richard Roe
FSDO "B"


Dear Mr. Roe,


Thank you for your response.


I appreciate humor as much as anyone, but I don't see how we
arrived "at the site of the crash". This operation presents no
undue hazard.


I'm aware that hand held GPS units are not approved for flight
into IFR conditions, and that GPS installations CAN be approved
for IFR flight. But after an extensive search, I cannot find any
regulation REQUIRING that GPS have that approval in order to
be used during IFR enroute flight.


You say that this operation would violate several FARs, could
you cite them please?


Sincerely,
Steven P. McNicoll


No further messages were received from FSDO "B".


From FSDO "C":


Dear Steve,


I am forwarding your question to our Avionics Inspector;
Apollo Garmin. This is in his area of expertise.


Thank you for using our website.


Guy Fawkes
FSDO "C"


Steve,


I got together with our Avionics Inspector and have an
answer for you.


"A PORTABLE GPS CANNOT BE APPROVED IN THE
AIRCRAFT FOR INSTRUMENT FLIGHT RULES (IFR) OR
VISUAL FLIGHT RULES UNLESS THE COMPLETE SYSTEM
IS INSTALLED AND EVALUATED IN ACCORDANCE WITH
THE INTERIM POLICY GUIDANCE DATED MARCH 20, 1992,
AS AMENDED, PERTAINING TO THE APPROVAL OF GPS
EQUIPMENT."


VFR only not IFR.


Let me know if we can be of any further assistance.


Guy Fawkes
FSDO "C"


Dear Mr. Fawkes,


Thank you for your response. I understand that a portable
GPS receiver cannot be approved for IFR flight, but what
regulation prohibits a non-approved GPS receiver from
being used during IFR flight?


Steven P. McNicoll


Steven,


Per my Avionics Inspector the following 14CFR Paragraph
answers your question (specifically para (b)(5):
----------------------------------
 91.21 _ Portable Electronic Devices.


(a) Except as provided in paragraph (b) of this section, no
person may operate, nor may any operator or pilot in command
of an aircraft allow the operation of, any portable electronic device
on any of the following U.S.-registered civil aircraft:


(1) Aircraft operated by a holder of an air carrier operating
certificate or an operating certificate; or


(2) Any other aircraft while it is operated under IFR.


(b) Paragraph (a) of this section does not apply to-


(1) Portable voice recorders;


(2) Hearing aids;


(3) Heart pacemakers;


(4) Electric shavers; or


(5) Any other portable electronic device that the operator of
the aircraft has determined will not cause interference with the
navigation or communication system of the aircraft on which it
is to be used.


(c) In the case of an aircraft operated by a holder of an air
carrier operating certificate or an operating certificate, the
determination required by paragraph (b)(5) of this section shall
be made by that operator of the aircraft on which the particular
device is to be used. In the case of other aircraft, the
determination may be made by the pilot in command or other
operator of the aircraft.
------------------------


Guy Fawkes
FSDO "C"


Dear Mr. Fawkes,


FAR 91.21(b)(5) permits the operation of any portable electronic
device, other than a portable voice recorder, hearing aid, heart pacemaker,
or electric shaver, that the operator of the aircraft has determined will
not cause interference with the navigation or communication system of the
aircraft on which it is to be used.
Recall that in my scenario I stated that I had previously determined
that my handheld GPS receiver does not cause interference with
the navigation or communication system on my airplane. It seems
to me that I have complied with FAR 91.21 to the letter.


Steven P. McNicoll


No further messages were received from FSDO "C"


From FSDO "D":


Dear Mr. Steven P. McNicoll


In response to your question, does this operation violate
any FAR?


Yes, it does.


You may file IFR as a (slant) /A.


The handheld GPS is not acceptable as RNAV and is contrary to:


14 Code of Federal Regulations(CFR), Part 21 sub part K and O.


14 CFR 23.1307


14 CFR 23.1309(b)


14 CFR 91.21


14 CFR 91.205


These are referenced in FAA pamphlet FAA-P-8000-3.


Thank you for your interest in aviation safety. Please call if you have any
questions, (987) 654-3210.


Inspector John Smith
FSDO "D"


Dear Mr. Smith,


Thank you for your response. Please see below for additional
questions and comments.


Steven P. McNicoll



> Dear Mr. Steven P. McNicoll


> In response to your question, does this operation violate
> any FAR?


> Yes, it does.


> You may file IFR as a (slant) /A.


> The handheld GPS is not acceptable as RNAV



What regulation specifies what is acceptable and what is not
acceptable as RNAV?


> and is contrary to:
> 14 Code of Federal Regulations(CFR), Part 21 sub part K and O.



How can that be? A handheld GPS is not a part or an appliance,
it is not installed in or attached to the aircraft. To my knowledge
there is no regulation that requires a GPS receiver to comply with
a TSO.


> 14 CFR 23.1307



I don't see how Part 23 is applicable at all, this does not involve
any change to a type certificate.

A handheld GPS receiver is not equipment necessary for the
airplane to operate at the maximum operating altitude or in the
kinds of operations and meteorological conditions for which it
is certified. Why would it need to be included in the type design?
Given that it is a portable device, how could it be included in the
type design?



> 14 CFR 23.1309(b)



14 CFR 23.1309(b) refers to installed equipment, but a
handheld GPS is not installed equipment.


> 14 CFR 91.21



Recall that I had previously determined my handheld GPS does
not cause interference with the navigation or communication
system on my airplane.


> 14 CFR 91.205



How is this regulation being violated? My aircraft contains all
of the instruments and equipment specified 14 CFR 91.205 for
IFR operations, and those instruments and items of equipment
are in operable condition.


> These are referenced in FAA pamphlet FAA-P-8000-3.



How may I obtain this pamphlet?


> Thank you for your interest in aviation safety.
> Please call if you have any questions, (987) 654-3210.


> Inspector John Smith
> FSDO "D"



Dear Mr. Steven P. McNicoll,

Your Bonanza was probably built in accordance with 14 CFR 23
(FAR 23), and if you intend to use the aircraft for IFR flight, it
should have the equipment specified in 14 CFR 91.205. The
hand-held GPS is not included in 91.205 because it is not
approved for IFR flight. In fact no GPS systems are mentioned
in 91.205, any GPS system that is approved for IFR use and is
going to be permanently installed in an aircraft needs to be
approved for that specific make and model of aircraft. The FAA
will not approve a GPS installation for IFR use if the GPS unit
wasn't manufactured to the minimum specifications of Technical
Standard Order-129A (TSO-C129A). At this point in time, no
hand-held GPS unit meets the minimum specifications spelled
out in TSO-C129A. TSO-C129A specifies the criteria by which
an installed GPS system, intended for certification in IFR
operations, will be built. A hand-held, portable GPS is not built
to these specifications.


The pamphlet(FAA-P-8000-3) we previously mentioned is available
at "http://gps.faa.gov/Library/gps1.pdf" on the Internet. In
FAA-P-8000-3, chapter 1, page 1-7, the first paragraph under
section 1.3. Hand-held or portable GPS receivers may be used
as a supplement to Visual Flight Rules only.


If you have any further questions you should contact your local F. A.
A. FSDO for more information. We are an Air Carrier Office and
deal with the airlines. Your local FSDO will have Inspectors who
deal with Part 91 operators. From the address on your e-mail it
appears that you are in the Milwaukee FSDO area. There phone
number is (414) 486-2920. They also have an Internet web-site.
The address is: "http://www.faa.gov/fsdo/mke".


Thank You,
Inspector John Smith
FSDO "D"


Dear Mr. Smith,


Thank you for your response. Please see additional comments
and questions below.


Sincerely,


Steven P. McNicoll



> Dear Mr. Steven P. McNicoll,


> Your Bonanza was probably built in accordance with
> 14 CFR 23 (FAR 23), and if you intend to use the aircraft
> for IFR flight, it should have the equipment specified in
> 14 CFR 91.205.



Please understand that this is a completely hypothetical scenario,
I do not own a Bonanza. My hypothetical Bonanza contains all of
the instruments and equipment specified in 14 CFR 91.205.


> The hand-held GPS is not included in 91.205 because it is
> not approved for IFR flight.



If my aircraft contains all of the instruments and equipment
specified in 14 CFR 91.205, then I am in compliance with that
regulation. What regulation prevents me from using a device
that is not mentioned in 91.205?


> In fact no GPS systems are mentioned in 91.205, any GPS
> system that is approved for IFR use and is going to be
> permanently installed in an aircraft needs to be approved for
> that specific make and model of aircraft. The FAA will not
> approve a GPS installation for IFR use if the GPS unit wasn't
> manufactured to the minimum specifications of Technical
> Standard Order-129A (TSO-C129A). At this point in time,
> no hand-held GPS unit meets the minimum specifications
> spelled out in TSO-C129A. TSO-C129A specifies the
> criteria by which an installed GPS system, intended for
> certification in IFR operations, will be built.


> A hand-held, portable GPS is not built to these specifications.



I understand that, but I can find no regulation that requires a GPS
receiver that is used for IFR enroute flight to be permanently
installed in the aircraft or to meet the specifications of TSO C-129a.


> The pamphlet(FAA-P-8000-3) we previously mentioned is
> available at "http://gps.faa.gov/Library/gps1.pdf" on the
> Internet.


> In FAA-P-8000-3, chapter 1, page 1-7, the first paragraph
> under section 1.3. Hand-held or portable GPS receivers
> may be used as a supplement to Visual Flight Rules only.



I don't believe that pamphlet has the force of law. The FAA
publishes the Federal Aviation Regulations (FARs) to make
readily available to the aviation community the regulatory
requirements placed upon them. If a GPS receiver that did
not meet the standards of TSO C-129a was not to be used
during IFR flight, then there would be an FAR that required
any GPS receiver used during IFR flight to meet that standard.


> If you have any further questions you should contact your local F. A.
> A. FSDO for more information. We are an Air Carrier Office and
> deal with the airlines. Your local FSDO will have Inspectors who
> deal with Part 91 operators. From the address on your e-mail it
> appears that you are in the Milwaukee FSDO area. There phone
> number is (414) 486-2920. They also have an Internet web-site.
> The address is: "http://www.faa.gov/fsdo/mke".


> Thank You,
> Inspector John Smith
> FSDO "D"



I have contacted eleven of the fourteen FSDOs in the Great Lakes Region. I
gave them all this same scenario and asked them all the
same question. Seven of them responded, all stating that
navigation by handheld GPS receiver during enroute flight under
IFR is illegal, but none of them could cite any law that would be
violated by such use! It seems to me that if it is illegal, then there
must be a regulation that is being violated; if there is no regulation
being violated, then it is not illegal.

Sincerely,
Steven P. McNicoll


No further messages were received from FSDO "D".

Steven P. McNicoll
May 8th 06, 04:50 PM
"Travis Marlatte" > wrote in message
om...
>
> No, it was yours, Sam. Whether you knew it or not. Steven simply picked up
> on your fairly inocent, but mistaken statement that ATC uses SERVICE
> VOLUMES to guide direct routing. You even referenced a table that is NOT
> based on service volumes.
>
> You both agree about the limitations on direct routing and Steven knows
> it. He just likes to nit pick the details.
>

Details are important. The difference between AGL and MSL altitude at many
navaid locations in the US can be several thousand feet.

Steven P. McNicoll
May 8th 06, 04:51 PM
"Sam Spade" > wrote in message
news:gmJ7g.175942$bm6.83898@fed1read04...
> Travis Marlatte wrote:
>
>> Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the
>> fact that Alaska has special rules does not mean anything for the other
>> 49 states.
>>
>
> But Part 95 is.
>

....irrelevant to the subject under discussion.

Sam Spade
May 8th 06, 04:51 PM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:pkp7g.175617$bm6.114407@fed1read04...
>
>>That is pure bull****. You brought up AGL, not me. I was referring to
>>7110.65, not the AIM.
>>
>
>
> You brought up service volumes. Are service volumes based on AGL or MSL
> altitudes?
>
>
For purposes of ATC handing as set forth in 7110.65, service volumes are
stated in MSL values.

Sam Spade
May 8th 06, 04:52 PM
Ted wrote:

> "Sam Spade" > wrote in message
> news:Pkp7g.175618$bm6.124940@fed1read04...
>
>
>>And, it's Stevie's assertion.
>
>
>>...That is pure bull****....
>
>
>>...You are either stupid or stubborn...
>
>
> Sam, does your mother wash your mouth out with soap when you try and use
> that language in front of her?
>
> Are you losing your grip, Sam?
>
> Perhaps you should take some valium and relax a bit before you attempt to
> continue this legal discussion as you are clearly overwhelmed by those who
> disagree with you?
>
>
>
>
>
No, it's playing with Steve on his terms.

Steven P. McNicoll
May 8th 06, 04:52 PM
"Sam Spade" > wrote in message
news:ZlJ7g.175941$bm6.31585@fed1read04...
>
> Bull****.
>

Pottymouth.

Sam Spade
May 8th 06, 04:55 PM
Travis Marlatte wrote:

> No, it was yours, Sam. Whether you knew it or not. Steven simply picked up
> on your fairly inocent, but mistaken statement that ATC uses SERVICE VOLUMES
> to guide direct routing. You even referenced a table that is NOT based on
> service volumes.
>
> You both agree about the limitations on direct routing and Steven knows it.
> He just likes to nit pick the details.
>
>
Those are the values derived from service volumes, so to call them
service volumes in the context of the 7110.65 is not only reasonable, it
is exactly what the authors of the 7110.65 do as follows:

"4-1-4. VFR-ON-TOP
Use a route not meeting service volume limitations only if an aircraft
requests to operate "VFR-on-top" on this route."

To attach precision to a patch-work document such as the 7110.65 is a
fool's errand.

Steven P. McNicoll
May 8th 06, 04:56 PM
"Sam Spade" > wrote in message
news:_NJ7g.175944$bm6.20748@fed1read04...
>
> For purposes of ATC handing as set forth in 7110.65, service volumes are
> stated in MSL values.
>

Service volumes are always stated in AGL values and are not used for
purposes of ATC handing as set forth in FAAO 7110.65.

Steven P. McNicoll
May 8th 06, 04:58 PM
"Sam Spade" > wrote in message
news:FOJ7g.175945$bm6.30359@fed1read04...
>
> No, it's playing with Steve on his terms.
>

Steve's terms are to present a cogent argument supported by verifiable
documentation. You don't play that way.

Tim Auckland
May 8th 06, 05:44 PM
On Mon, 08 May 2006 08:59:03 -0400, Roy Smith > wrote:

>
>While the AIM may not be regulatory, it also doesn't lie. When a simple
>declaratory statement is made such as, "hand-held GPS systems are not
>authorized for IFR navigation, instrument approaches, or as a principal
>instrument flight reference", it's a pretty good guess that there is some
>regulation, somewhere that backs that up.

As Steven has so often pointed out, nobody has been able to cite that
regulation.

I applaud John Deakin and Steven for challenging commnonly held
assumptions they believe to be wrong, even if they do it in their own
particular style. It's one of the ways in which we learn.

>Anybody who feels confident
>enough that handheld GPS is good enough for IFR is welcome to invite an
>FSDO guy to ride along with you for an inspection with a handheld as your
>sole means of IFR navigation outside of DR, vectors, celestial, and a ham
>sandwich. See how far you get. Then please post about it so we can all
>share in your experience.
>
>Until that time, all this talk about how the AIM is not regulatory and how
>it's OK to fly IFR with a handheld is just a lot of masturbation.

No it's not. Chances are that you'd get a FSDO guy who assumes that
the AIM statement is based on a FAR. It's not worth the hassle or
expense of an airplane flight to try to persuade this one guy
otherwise.

What you do in the real world is up to you. Personally, on
reflection, I'd use the GPS to get the heading I want to fly, then ask
ATC for that vector. I believe the Direct routing is legal, but I see
no reason to stir up a possible hornet's nest in the air when the
alternative is so simple.

Tim.

Frank Ch. Eigler
May 8th 06, 06:05 PM
"Steven P. McNicoll" > writes:

> > The hand-held GPS is not included in 91.205 because it is
> > not approved for IFR flight.
>
> If my aircraft contains all of the instruments and equipment
> specified in 14 CFR 91.205, then I am in compliance with that
> regulation. [...]

Perhaps your scenario is self-contradictory. 91.205.d.2 appears to
require "... navigational equipment appropriate to the ground
facilities to be used ...". If you're filing to a far-away ground
facility (far away airport or navaid) that you don't have appropriate
nagivational equipment (super-duper VOR receiver or substitutable GPS)
to guide yourself to, you may be in violation right there.

It may be interesting to other readers that in other parts of the
world, it is sometimes required to carry sufficient *extra*
navigational equipment that would enable an instrument letdown to an
alternate in the case of a failure of any one.

- FChE

Steven P. McNicoll
May 8th 06, 06:24 PM
"Frank Ch. Eigler" > wrote in message
...
>
> Perhaps your scenario is self-contradictory. 91.205.d.2 appears to
> require "... navigational equipment appropriate to the ground
> facilities to be used ...". If you're filing to a far-away ground
> facility (far away airport or navaid) that you don't have appropriate
> nagivational equipment (super-duper VOR receiver or substitutable GPS)
> to guide yourself to, you may be in violation right there.
>

I'm in full compliance with FAR 91.205 in that regard, I have two fully
functional VOR receivers aboard.

Ron Lee
May 8th 06, 06:26 PM
"Steven P. McNicoll" > wrote:

>
>"Ron Lee" > wrote in message
...
>>
>> A primary reason that handheld/VFR GPS units are not acceptable for
>> VFR use is that they not not include an integrity capability. That is
>> essential for IFR ops.
>>
>
>Can you explain why that is so?

Let me ask you a few things.

1) Are you aware that the clocks onboard a GPS satellite can
malfunction?

2) Are you aware that when a malfunction occurs that the users' GPS
unit derived position can drift off by hundreds or thousands of miles?

3) Are you aware that the pilot may well have ZERO indication of that
failure without an integrity functionality in his user equipment?

If your responses are "So," "So," and "So" then I have no desire to
ever fly with you if you are a pilot.

Ron Lee

Steven P. McNicoll
May 8th 06, 06:30 PM
"Ron Lee" > wrote in message
...
> "Steven P. McNicoll" > wrote:
>
>>
>>"Ron Lee" > wrote in message
...
>>>
>>> A primary reason that handheld/VFR GPS units are not acceptable for
>>> VFR use is that they not not include an integrity capability. That is
>>> essential for IFR ops.
>>>
>>
>>Can you explain why that is so?
>>
>
> Let me ask you a few things.
>
> 1) Are you aware that the clocks onboard a GPS satellite can
> malfunction?
>
> 2) Are you aware that when a malfunction occurs that the users' GPS
> unit derived position can drift off by hundreds or thousands of miles?
>
> 3) Are you aware that the pilot may well have ZERO indication of that
> failure without an integrity functionality in his user equipment?
>
> If your responses are "So," "So," and "So" then I have no desire to
> ever fly with you if you are a pilot.
>

I'm aware that anything can malfunction. I've answered your questions, it's
time for you to answer mine.

Frank Ch. Eigler
May 8th 06, 06:39 PM
"Steven P. McNicoll" > writes:

> > Perhaps your scenario is self-contradictory. 91.205.d.2 appears to
> > require "... navigational equipment appropriate to the ground
> > facilities to be used ...". [...]
>
> I'm in full compliance with FAR 91.205 in that regard, I have two fully
> functional VOR receivers aboard.

But those ordinary VOR receivers will do approximately nothing for
you, when flying direct to a faraway VOR they cannot pick up yet, thus
they are not "appropriate to the ground facilities to be used".

- FChE

Mark Hansen
May 8th 06, 06:45 PM
On 05/08/06 10:39, Frank Ch. Eigler wrote:
> "Steven P. McNicoll" > writes:
>
>> > Perhaps your scenario is self-contradictory. 91.205.d.2 appears to
>> > require "... navigational equipment appropriate to the ground
>> > facilities to be used ...". [...]
>>
>> I'm in full compliance with FAR 91.205 in that regard, I have two fully
>> functional VOR receivers aboard.
>
> But those ordinary VOR receivers will do approximately nothing for
> you, when flying direct to a faraway VOR they cannot pick up yet, thus
> they are not "appropriate to the ground facilities to be used".
>
> - FChE

I think the point is that no ground facilities are being used for the
direct-to part of the flight. You're assuming that he is using the VOR
receiver to go direct-to a VOR 1000 miles away, but he's already said
that he was using the GPS.


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

Steven P. McNicoll
May 8th 06, 07:08 PM
"Frank Ch. Eigler" > wrote in message
...
>
> But those ordinary VOR receivers will do approximately nothing for
> you, when flying direct to a faraway VOR they cannot pick up yet, thus
> they are not "appropriate to the ground facilities to be used".
>

They're fully appropriate when I'm actually using them.

Ron Lee
May 8th 06, 10:18 PM
>I'm aware that anything can malfunction. I've answered your questions, it's
>time for you to answer mine.

You have neither answered my questions nor done what I suggested. Why
not?

Ron Lee

Dane Spearing
May 8th 06, 10:43 PM
In article >,
Steven P. McNicoll > wrote:
> wrote in message
oups.com...
>> So if the AIM says that handhelds are not authorized for IFR
>> navigation, there must be a rule somewhere, right?
>
>One would think so, but there isn't.

There's a lot of stuff in the AIM that isn't backed up by a rule in the FARs.
My favorite example is "Land and Hold Short" operations. There's nothing
in the FARs about this, but the AIM explains it at length, including the
"requirement" to read back all hold short instructions. So, if it's not in the
FARs, then I don't actually have to read back that hold short instruction,
right?!? (Yeah...try that at a busy airport and see how far you get...)

-- Dane

Dane Spearing
May 8th 06, 11:00 PM
In article >,
Steven P. McNicoll > wrote:
> wrote in message
oups.com...
>>
>> I suppose this means that this has come up before and you have a good
>> counterpoint for it? Besides throwing out the entire AIM, I hope.
>>
>
>Oh, it's come up many times. This is like a religion with some people, a
>matter of faith. They insist use of handheld GPS during IFR enroute
>operations in US controlled airspace is illegal and/or unsafe but none of
>them can identify any regulation that prohibits it or any hazard caused by
>such use.

<sigh> I guess I don't understand why someone would want to intentionally
operate outside of those guidelines set out in the AIM (barring an emergency
or other detriment to flight safety).

You are correct...there is no "regulation" (i.e. - rule in the FARs) that
state you can not use a hand-held GPS for IFR navigation. However, the
non-regulatory AIM makes it very clear. As I mentioned in a previous post,
there's also nothing in the FARs about requiring you to read back a hold
short instruction....just the AIM.

I'm certainly no legal expert (nor would I ever want to be), so I can't
make a professional interpretation as to the regulatory or legal status
of things like the AIM, Advisory Circulars, etc... However, it seems
reckless and irresponsible to operate outside of those guidelines.

You are also correct in that there is nothing that says that use of
a handheld for IFR operations is unsafe. However, more importantly,
there's nothing to indicate that it *is* safe! The TSO process exists
for a reason: to prove, via a documented and certified process, that
a piece of avionics will do what it is supposed to do, when it is supposed
to do it.

It's more a matter of faith to assume that the hand-held *is* safe and
will do what it's supposed to do than to assume it is illegal and/or unsafe.

-- Dane

Mark Hansen
May 8th 06, 11:03 PM
On 05/08/06 14:43, Dane Spearing wrote:
> In article >,
> Steven P. McNicoll > wrote:
> wrote in message
oups.com...
>>> So if the AIM says that handhelds are not authorized for IFR
>>> navigation, there must be a rule somewhere, right?
>>
>>One would think so, but there isn't.
>
> There's a lot of stuff in the AIM that isn't backed up by a rule in the FARs.
> My favorite example is "Land and Hold Short" operations. There's nothing
> in the FARs about this, but the AIM explains it at length, including the
> "requirement" to read back all hold short instructions. So, if it's not in the
> FARs, then I don't actually have to read back that hold short instruction,
> right?!? (Yeah...try that at a busy airport and see how far you get...)
>
> -- Dane

I suspect if you don't read it back, you won't be cleared to land. If
you land anyway, you're violating an FAR. If you want to land, you'd
better read it back.

Perhaps in this case, there is no need for an FAR?

.... not a good example, then.


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

Jon Woellhaf
May 8th 06, 11:21 PM
Dane Spearing wrote
> ... The TSO process exists
> for a reason: to prove, via a documented and certified process, that
> a piece of avionics will do what it is supposed to do, when it is supposed
> to do it.

Ha, ha, ha, ha, ha. Good one. But you forgot the smiley face. <g>

Dane Spearing
May 9th 06, 12:45 AM
In article >,
Jon Woellhaf > wrote:
>Dane Spearing wrote
>> ... The TSO process exists
>> for a reason: to prove, via a documented and certified process, that
>> a piece of avionics will do what it is supposed to do, when it is supposed
>> to do it.
>
>Ha, ha, ha, ha, ha. Good one. But you forgot the smiley face. <g>

:) There. Happy now?!? :)

(Well, that *is* what the TSO process is *supposed* to be for....I never said
that it actually accomplished that goal....) :)

-- Dane

Matt Barrow
May 9th 06, 03:37 AM
"Dane Spearing" > wrote in message
...
>
> You are correct...there is no "regulation" (i.e. - rule in the FARs) that
> state you can not use a hand-held GPS for IFR navigation.

Correct...as the SOLE REFERENCE.

> However, the
> non-regulatory AIM makes it very clear. As I mentioned in a previous
> post,
> there's also nothing in the FARs about requiring you to read back a hold
> short instruction....just the AIM.

TSO 129 requirement for IFR instruments?

Even seven years old, this article is relevant:
http://www.avweb.com/news/columns/182076-1.html
November 29, 1998

Pelican's Perch #11:
Using a Handheld GPS — IFR!

/--

Never one to let a good idea, or safer method of flying, wither away for
lack of action or misunderstanding, AVweb's John Deakin takes on the subject
of flying IFR with your GPS handheld. "Not legal," you say? "Not so," says
John. Flying IFR with your handheld GPS is not only legal, it's a godsend he
says, and explains just how to get the most out of that handful of
navigation wizardry.

/--

Steven P. McNicoll
May 9th 06, 04:32 AM
"Ron Lee" > wrote in message
...
>
> You have neither answered my questions nor done what I suggested. Why
> not?
>

Your "questions" were actually one question. I answered them when I said
anything can malfunction. I'll do what you suggested after you send me
money to pay for the flight.

I'm left to conclude you cannot answer my question.

Steven P. McNicoll
May 9th 06, 04:48 AM
"Dane Spearing" > wrote in message
...
>
> <sigh> I guess I don't understand why someone would want to intentionally
> operate outside of those guidelines set out in the AIM (barring an
> emergency
> or other detriment to flight safety).
>

Because direct flight is quicker than following the airways and handheld GPS
is cheaper to purchase.


>
> You are correct...there is no "regulation" (i.e. - rule in the FARs) that
> state you can not use a hand-held GPS for IFR navigation. However, the
> non-regulatory AIM makes it very clear. As I mentioned in a previous
> post,
> there's also nothing in the FARs about requiring you to read back a hold
> short instruction....just the AIM.
>

Does reading back a hold short instruction need to be in the FARs? ATC is
required to get the readback. If you don't read back the hold short ATC is
going to instruct you to do something other than what you want to do until
you do read it back and there is something in the FARs about adhering to ATC
instructions.


>
> I'm certainly no legal expert (nor would I ever want to be), so I can't
> make a professional interpretation as to the regulatory or legal status
> of things like the AIM, Advisory Circulars, etc... However, it seems
> reckless and irresponsible to operate outside of those guidelines.
>

What's to interpret? The AIM itself says it's not regulatory and the
Advisory Circular Checklist says that unless incorporated into a regulation
by reference the contents of an advisory circular are not binding on the
public.


>
> You are also correct in that there is nothing that says that use of
> a handheld for IFR operations is unsafe. However, more importantly,
> there's nothing to indicate that it *is* safe!
>

The absence of any danger or harm from it's use indicates it is safe.


>
> It's more a matter of faith to assume that the hand-held *is* safe and
> will do what it's supposed to do than to assume it is illegal and/or
> unsafe.
>

We don't assume it's safe, we know it's safe because even a complete failure
of a handheld GPS during IFR enroute flight in US controlled airspace
presents no danger.

Steven P. McNicoll
May 9th 06, 04:50 AM
"Dane Spearing" > wrote in message
...
>
> There's a lot of stuff in the AIM that isn't backed up by a rule in the
> FARs.
> My favorite example is "Land and Hold Short" operations. There's nothing
> in the FARs about this, but the AIM explains it at length, including the
> "requirement" to read back all hold short instructions. So, if it's not
> in the
> FARs, then I don't actually have to read back that hold short instruction,
> right?!? (Yeah...try that at a busy airport and see how far you get...)
>

You only have to read it back if you wish to land at that airport.

Sam Spade
May 9th 06, 11:07 AM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:gmJ7g.175942$bm6.83898@fed1read04...
>
>>Travis Marlatte wrote:
>>
>>
>>>Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the
>>>fact that Alaska has special rules does not mean anything for the other
>>>49 states.
>>>
>>
>>But Part 95 is.
>>
>
>
> ...irrelevant to the subject under discussion.
>
>
That is your opinion, which (as is often the case) contrary to the facts.

Steven P. McNicoll
May 9th 06, 11:53 AM
"Sam Spade" > wrote in message
news:JRZ7g.176003$bm6.52932@fed1read04...
>
> That is your opinion, which (as is often the case) contrary to the facts.
>

Cite the cases.

Travis Marlatte
May 9th 06, 12:51 PM
Foul language aside, the definition of an airway is separate from the
regulation of how to track an airway.


--
-------------------------------
Travis
Lake N3094P
KPWK


"Sam Spade" > wrote in message
news:ZlJ7g.175941$bm6.31585@fed1read04...
> Steven P. McNicoll wrote:
>
>> "Sam Spade" > wrote in message
>> news:Wip7g.175615$bm6.36868@fed1read04...
>>
>>>You are either stupid or stubborn, or perhaps both.
>>
>>
>> I am neither.
>>
>>
>>
>>>The AIM reference is explanatory.
>>
>>
>> The AIM is not regulatory.
>>
>>
>>
>>>The 8260-16, when describing Federal Airwaty V-XXX, which is formed by
>>>VOR facilities, is regulatory.
>>>
>>
>>
>> Irrelevant to the subject under discussion.
> Bull****.

Bob Noel
May 9th 06, 12:54 PM
In article >,
"Travis Marlatte" > wrote:

> Foul language aside, the definition of an airway is separate from the
> regulation of how to track an airway.

isn't there a relationship?

--
Bob Noel
Looking for a sig the
lawyers will hate

Travis Marlatte
May 9th 06, 12:56 PM
Part 95 is what? Regulatory? I agree.

Part 95 talks about altitudes, not tracking airways. Part 95 talks about
altitudes in Alaska. Not the lower 48.

Part 95 is irrelevant to the discussion at hand.

Steven is correct. There is no regulation or set of regulations that require
certified GPS for IFR flight.

I have a certified GPS. I want the RAIM capability. However, I would not
hestitate to use a handheld to track a direct route - as long as I could
back it up with other ground-based fixes. I even back up my certified GPS
with ground-based fixes.

--
-------------------------------
Travis
Lake N3094P
PWK
"Sam Spade" > wrote in message
news:gmJ7g.175942$bm6.83898@fed1read04...
> Travis Marlatte wrote:
>
>> Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the
>> fact that Alaska has special rules does not mean anything for the other
>> 49 states.
>>
> But Part 95 is.

Sam Spade
May 9th 06, 01:19 PM
Travis Marlatte wrote:

> Part 95 is what? Regulatory? I agree.
>
> Part 95 talks about altitudes, not tracking airways. Part 95 talks about
> altitudes in Alaska. Not the lower 48.
>
> Part 95 is irrelevant to the discussion at hand.

You don't understand how Part 95 works.

Part 95 governs IFR Altitudes in all 50 states and other areas under FAA
jurisdiction, not just Alaska. Where did you get the idea it covers
only Alaska?

IFR Alitudes = MEAs, MRAs, MOCAs, MCAs. Those are the altitudes of
airways. Airways are issued under Part 95 via the federal register via
incorporation by reference, exactly like instrument approach procedures
(Part 97).

The *regulatory* source document for an airway specifies the required
VOR stations, among other things.

The analogy is a VOR approach at PDQ Airport. You cannot fly that
approach using ADF, for example.

Sam Spade
May 9th 06, 01:20 PM
In your usual evasive style I noticed you ignored my post about service
volumnes and VFR on top.

Matt Barrow
May 9th 06, 02:46 PM
"Sam Spade" > wrote in message
news:FO%7g.176005$bm6.51757@fed1read04...
>
>
> In your usual evasive style I noticed you ignored my post about service
> volumnes and VFR on top.

Based on your post, he evaded EVERYTHING (i.e., original post is totally
blank).

Sam Spade
May 9th 06, 03:01 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:XSg7g.175495$bm6.14199@fed1read04...
>
>>And, we hope it is applied.
>>
>
>
> Application is not optional.
>
>
So long as no one forgets or makes a mistake.

Ron Lee
May 9th 06, 03:48 PM
"Steven P. McNicoll" > wrote:

>
>"Ron Lee" > wrote in message
...
>>
>> You have neither answered my questions nor done what I suggested. Why
>> not?
>>
>
>Your "questions" were actually one question. I answered them when I said
>anything can malfunction. I'll do what you suggested after you send me
>money to pay for the flight.
>
>I'm left to conclude you cannot answer my question.

I'm left to conclude that you are not a pilot to entrust with anyone's
life. Do you need a reg to tell you not to fly into thunderstorms?
Do you need a reg to tell you not to fly into known icing conditions
with an aircraft not approved for it?

Do as you wish. Just don't take anyone with you should you fall prey
to Darwinism.

Ron Lee

Steven P. McNicoll
May 9th 06, 04:09 PM
"Ron Lee" > wrote in message
...
>
> I'm left to conclude that you are not a pilot to entrust with anyone's
> life.
>

Upon what do you base that conclusion?


>
> Do you need a reg to tell you not to fly into thunderstorms?
>

Nope. Do you?


>
> Do you need a reg to tell you not to fly into known icing conditions
> with an aircraft not approved for it?
>

Nope do you?


>
> Do as you wish. Just don't take anyone with you should you fall prey
> to Darwinism.
>

Do you see any similarity at all between flying into thunderstorms or flying
into known icing conditions with an aircraft not approved for it and
enroute IFR navigation by handheld GPS in US controlled airspace?

Frank Ch. Eigler
May 9th 06, 04:46 PM
"Steven P. McNicoll" wrote:

> > But those ordinary VOR receivers will do approximately nothing for
> > you, when flying direct to a faraway VOR they cannot pick up yet, thus
> > they are not "appropriate to the ground facilities to be used".
>
> They're fully appropriate when I'm actually using them.

This rather Clintonian argument ("to be used" vs "I wish to use")
opens the door to kooky things like flying an ILS with a handheld GPS.
("Sure I have one on board, but the FARs don't say I have to USE it
...."), or ignoring monitoring instruments ("my engine oil temp may
have been at redline, but I don't have to LOOK at it").

A 91.13 citation would fit perfectly, should something go wrong.

- FChE

Steven P. McNicoll
May 9th 06, 05:19 PM
"Frank Ch. Eigler" > wrote in message
...

Folks, take notice of the absurd lengths the true believers have to go to
justify their faith.



>
> This rather Clintonian argument ("to be used" vs "I wish to use")
> opens the door to kooky things like flying an ILS with a handheld GPS.
> ("Sure I have one on board, but the FARs don't say I have to USE it
> ..."), or ignoring monitoring instruments ("my engine oil temp may
> have been at redline, but I don't have to LOOK at it").
>

How would it open that door? Why would anyone attempt to fly an ILS with a
GPS of any kind instead of the LOC and GS receivers? I've already pointed
out that I'm in full compliance with FAR 91.205, I have navigational
equipment appropriate to all the ground facilities that may be used.


>
> A 91.13 citation would fit perfectly, should something go wrong.
>

Actually, it wouldn't fit at all. FAR 91.13 applies to operation of an
aircraft in a careless or reckless manner so as to endanger the life or
property of another.

May 9th 06, 09:01 PM
Ron Lee wrote:
>
> I'm left to conclude that you are not a pilot to entrust with anyone's
> life. Do you need a reg to tell you not to fly into thunderstorms?
> Do you need a reg to tell you not to fly into known icing conditions
> with an aircraft not approved for it?
>
> Do as you wish. Just don't take anyone with you should you fall prey
> to Darwinism.
>
> Ron Lee

So you now assume that navigating direct with a handheld GPS is
dangerous? Why is that? I can understand why people disagree whether
its "legal" or not, but safety? And pushing RAIM won't convince me.
I've seen almost as many IFR panel mount units give unreliable data or
drop out unexpectedly as I have seen that happen in handhelds. And
just a couple of days ago someone related the story in another thread
regarding his glideslope instrumentation going bad and causing the
autopilot, on a coupled ILS, to reach DH some two miles early. I'd
call that a safety issue.

Bob Noel
May 9th 06, 11:15 PM
In article . com>,
wrote:

> So you now assume that navigating direct with a handheld GPS is
> dangerous? Why is that? I can understand why people disagree whether
> its "legal" or not, but safety? And pushing RAIM won't convince me.

If you don't understand RAIM, then why bother asking about safety?

--
Bob Noel
Looking for a sig the
lawyers will hate

May 10th 06, 12:13 AM
Bob Noel wrote:
> If you don't understand RAIM, then why bother asking about safety?

I didn't say I didn't understand RAIM. I just don't care. I am not
convinced that it is necessary for enroute navigation that can be
"safely" accomplished with 30-year old VOR receivers.

My question is how is using a handheld GPS while in radar contact
unsafe? Or more to the point, how is it less safe than using a
combination of radar vectors and VORs? Is "fly heading 320, direct XYZ
VOR when able" any safer?

Sure a panel-mount TSOed IFR approved GPS is supposed to tell you when
its got an inconsistent solution of your position, and therefore it is
more reliable than a handheld, but we're not comparing panel mounts
with handhelds. We're comparing ADF/VOR navigation with handheld GPS.

Peter

Bob Noel
May 10th 06, 12:55 AM
In article om>,
wrote:

> Bob Noel wrote:
> > If you don't understand RAIM, then why bother asking about safety?
>
> I didn't say I didn't understand RAIM. I just don't care. I am not
> convinced that it is necessary for enroute navigation that can be
> "safely" accomplished with 30-year old VOR receivers.

It seems to me that you've already made up your mind wrt safety.

--
Bob Noel
Looking for a sig the
lawyers will hate

May 10th 06, 01:08 AM
Bob Noel wrote:

> It seems to me that you've already made up your mind wrt safety.

I have an opinion. That's not the same as being closed-minded. I'm
happy to hear the other side of the argument if you'd care to write it
down instead of just snapping back at me with one-liners.

Sam Spade
May 10th 06, 02:18 AM
wrote:

> So you now assume that navigating direct with a handheld GPS is
> dangerous? Why is that? I can understand why people disagree whether
> its "legal" or not, but safety? And pushing RAIM won't convince me.
> I've seen almost as many IFR panel mount units give unreliable data or
> drop out unexpectedly as I have seen that happen in handhelds. And
> just a couple of days ago someone related the story in another thread
> regarding his glideslope instrumentation going bad and causing the
> autopilot, on a coupled ILS, to reach DH some two miles early. I'd
> call that a safety issue.
>

When you bring up the ILS G/S you are taking on precision vertical
navigation, which is a different issue.

"Light Tin" approach couplers and ILS G/S installations have been an
issue for as long as I have been flying.

So, just because someone couldn't manage marginal couplers or G/S
receivers/antenna installations is really not relevant to use of
handhelds for IFR.

And, here the issue in the thread has primarily been legal, not safety.

I have argued with Ron before that, given reasonable, personal integrety
checks, I would be safer flying a VOR overlay approach with my Garmin
296 than with a light tin VOR receiver.

Sam Spade
May 10th 06, 02:21 AM
wrote:

> Bob Noel wrote:
>
>
>>It seems to me that you've already made up your mind wrt safety.
>
>
> I have an opinion. That's not the same as being closed-minded. I'm
> happy to hear the other side of the argument if you'd care to write it
> down instead of just snapping back at me with one-liners.
>
It is perfectly safe to use a good handheld for en route in most
circumstances, provided the antenna is located correctly, and so forth.

En route RAIM is a very loose spec, compared to approach RAIM.

But, the issue here is legality.

Then, there is the question of having a current database, more for
safety than legality in this case.

Bob Noel
May 10th 06, 02:28 AM
In article om>,
wrote:

> Bob Noel wrote:
>
> > It seems to me that you've already made up your mind wrt safety.
>
> I have an opinion. That's not the same as being closed-minded. I'm
> happy to hear the other side of the argument if you'd care to write it
> down instead of just snapping back at me with one-liners.

Do you think that we should look for improvements in safety or are you
of the opinion that the level of safety of, say, 1950 is sufficient today?
(this isn't a one-liner - just starting the dialog).

--
Bob Noel
Looking for a sig the
lawyers will hate

Ron Lee
May 10th 06, 02:40 AM
>I have argued with Ron before that, given reasonable, personal integrety
> checks, I would be safer flying a VOR overlay approach with my Garmin
>296 than with a light tin VOR receiver.

I won't disagree that when each system is working properly, an
approach with GPS (especially a moving map), is easier (thus perhaps
safer) than a VOR approach. But the point is that if a GPS satellite
malfunctions all bets are off. Hence the need for RAIM or equivalent.

Ron Lee

Steven P. McNicoll
May 10th 06, 03:45 AM
"Bob Noel" > wrote in message
...
>
> If you don't understand RAIM, then why bother asking about safety?
>

Nothing in his message suggested he doesn't understand RAIM.

Steven P. McNicoll
May 10th 06, 03:48 AM
"Sam Spade" > wrote in message
news:oeb8g.176055$bm6.60789@fed1read04...
>
> It is perfectly safe to use a good handheld for en route in most
> circumstances, provided the antenna is located correctly, and so forth.
>
> En route RAIM is a very loose spec, compared to approach RAIM.
>
> But, the issue here is legality.
>
> Then, there is the question of having a current database, more for safety
> than legality in this case.
>

Legality isn't an issue either. Since use of a handheld GPS during IFR
enroute flight in US controlled airspace does not by itself violate any FAR
it is perfectly legal.

May 10th 06, 04:50 AM
Bob Noel wrote:
> Do you think that we should look for improvements in safety or are you
> of the opinion that the level of safety of, say, 1950 is sufficient today?
> (this isn't a one-liner - just starting the dialog).
>
> --
> Bob Noel
> Looking for a sig the
> lawyers will hate

Yeah, I agree. Safety improvements are great. So how is safety
improved by telling people with perfectly good handheld GPSs that they
must stay on the airways and navigate with their VORs?

Bob Noel
May 10th 06, 07:18 AM
In article . com>,
wrote:

> Yeah, I agree. Safety improvements are great.

The tone of your reply makes me wonder...

>So how is safety
> improved by telling people with perfectly good handheld GPSs

How do you KNOW that the handheld GPS is "perfectly good"?




>that they
> must stay on the airways and navigate with their VORs?

Who said they have to?

--
Bob Noel
Looking for a sig the
lawyers will hate

May 10th 06, 08:58 AM
Bob Noel wrote:
> In article . com>,
> wrote:
>
> > Yeah, I agree. Safety improvements are great.
>
> The tone of your reply makes me wonder...

The tone is there because I'm still waiting to see why you think using
handhelds is unsafe. In many ways they add tremendously to safety,
especially the newer incarnations that depict terrain and weather. And
you probably agree that they are a great aid to situational awareness.
Why not, then, use them to help in certain navigation tasks as well?

Do you have data that shows that handheld GPS units are not more
reliable and dependable than the old VOR/DME/ADF system?

>
> >So how is safety
> > improved by telling people with perfectly good handheld GPSs
>
> How do you KNOW that the handheld GPS is "perfectly good"?

Because the occasional failure is not a significant impact on safety.
Between the pilot and controller monitoring the flight, errors will be
caught. It doesn't have to be perfect to be "perfectly good", I guess
that was a poor choice of adjectives on my part.

How do you know any piece of avionics is working right? Some are more
reliable than others, but all can fail. Even panel mount GPS units
with RAIM. They can fail for various reasons that the RAIM algorithm
will not predict. It is supposed to prevent the pilot from using
erroneous data, and most of the time it probably does. But just
because they are "safer" than handhelds doesn't make handhelds unsafe,
doesn't it?

I'll agree that a GPS with RAIM is better than one without. Now, I
don't know the details, but I have read that WAAS has better fault
monitoring than standard GPS+RAIM. Does that mean that all those poor
sods out there flying IFR with their Garmin 430/530 units are being
unsafe?

And what about those handhelds that use WAAS? I don't know if they do,
but if they did have the full fault-monitoring capabilities, would
those be "safe" in your view?

> >that they
> > must stay on the airways and navigate with their VORs?
>
> Who said they have to?

I was asking you a question. What is your view? If it is unsafe to
use your handheld to navigate direct, what are the choices that you
think are still "safe" for off-airway flights?

Peter

Ted
May 10th 06, 01:52 PM
"Ron Lee" > wrote in message
...
> >I have argued with Ron before that, given reasonable, personal integrety
>> checks, I would be safer flying a VOR overlay approach with my Garmin
>>296 than with a light tin VOR receiver.
>
> I won't disagree that when each system is working properly, an
> approach with GPS (especially a moving map), is easier (thus perhaps
> safer) than a VOR approach. But the point is that if a GPS satellite
> malfunctions all bets are off. Hence the need for RAIM or equivalent.
>
> Ron Lee
>

Is RAIM the only thing that can do that job?

Does WAAS identify a failed satellite and compensate for it?

Ron Lee
May 10th 06, 03:03 PM
"Ted" > wrote:

>
>"Ron Lee" > wrote in message
...
>> >I have argued with Ron before that, given reasonable, personal integrety
>>> checks, I would be safer flying a VOR overlay approach with my Garmin
>>>296 than with a light tin VOR receiver.
>>
>> I won't disagree that when each system is working properly, an
>> approach with GPS (especially a moving map), is easier (thus perhaps
>> safer) than a VOR approach. But the point is that if a GPS satellite
>> malfunctions all bets are off. Hence the need for RAIM or equivalent.
>>
>> Ron Lee
>>
>
>Is RAIM the only thing that can do that job?
>
>Does WAAS identify a failed satellite and compensate for it?

Yes WAAS takes care of the integrity requirement.

Ron Lee

Ron Lee
May 10th 06, 08:40 PM
wrote:

>Ron Lee wrote:
>
>> Yes WAAS takes care of the integrity requirement.
>
>Even on a handheld like the Garmin 296/396 models?

You need to consult the manual. If they use WAAS it would seem
logical to take advantage of the WAAS integrity functionality. That
does not make them suitable for IFR use.

Ron Lee
>

Steven P. McNicoll
May 10th 06, 11:11 PM
"Ron Lee" > wrote in message
...
> wrote:
>
> You need to consult the manual. If they use WAAS it would seem
> logical to take advantage of the WAAS integrity functionality. That
> does not make them suitable for IFR use.
>

Why not?

Sam Spade
May 11th 06, 02:19 AM
wrote:
> Ron Lee wrote:
>
>
>>Yes WAAS takes care of the integrity requirement.
>
>
> Even on a handheld like the Garmin 296/396 models?
>

Because it is a VFR unit, you have no assurance that the method by which
the 296/396 employs WAAS provides the required integrity.

Unless Garmin has a presence on this forum, no one can answer your
question with much of anything other than opinions.

The folks are Garmin who engineer the aviation handhelds are part of the
same group that make GPS units for hikers, automobiles, etc; i.e. what
Garmin calls the "Consumer Products" group.

Ron Lee
May 11th 06, 01:49 PM
Sam Spade > wrote:

wrote:
>> Ron Lee wrote:
>>
>>>Yes WAAS takes care of the integrity requirement.
>>
>> Even on a handheld like the Garmin 296/396 models?
>>
>Because it is a VFR unit, you have no assurance that the method by which
>the 296/396 employs WAAS provides the required integrity.
>
>Unless Garmin has a presence on this forum, no one can answer your
>question with much of anything other than opinions.
>
>The folks are Garmin who engineer the aviation handhelds are part of the
>same group that make GPS units for hikers, automobiles, etc; i.e. what
>Garmin calls the "Consumer Products" group.
>
Thanks Sam. Hopefully one of my responses was not misleading. WAAS
does make up for aviation integrity requirements that are not designed
into current GPS satellites. But for IFR flight, it assumes the
proper user equipment as well (I forget the applicable TSO).

Ron Lee

Ted
May 11th 06, 02:05 PM
"Steven P. McNicoll" > wrote in message
nk.net...
>
> "Ron Lee" > wrote in message
> ...
>> wrote:
>>
>> You need to consult the manual. If they use WAAS it would seem
>> logical to take advantage of the WAAS integrity functionality. That
>> does not make them suitable for IFR use.
>>
>
> Why not?
>

Because it would offend Allah!

Travis Marlatte
May 11th 06, 02:06 PM
As you say, part 95 governs IFR altitudes - not tracking airways. It does
not define airways nor how to track them. It defines altitudes to be used
when on and off airways.

Part 95 is irrelevant to the discussion at hand. There are no regulations
that prohibit the use of a non-certified GPS in IFR flight.

--
-------------------------------
Travis
Lake N3094P
PWK


"Sam Spade" > wrote in message
news:eN%7g.176004$bm6.15516@fed1read04...
> Travis Marlatte wrote:
>
>> Part 95 is what? Regulatory? I agree.
>>
>> Part 95 talks about altitudes, not tracking airways. Part 95 talks about
>> altitudes in Alaska. Not the lower 48.
>>
>> Part 95 is irrelevant to the discussion at hand.
>
> You don't understand how Part 95 works.
>
> Part 95 governs IFR Altitudes in all 50 states and other areas under FAA
> jurisdiction, not just Alaska. Where did you get the idea it covers only
> Alaska?
>
> IFR Alitudes = MEAs, MRAs, MOCAs, MCAs. Those are the altitudes of
> airways. Airways are issued under Part 95 via the federal register via
> incorporation by reference, exactly like instrument approach procedures
> (Part 97).
>
> The *regulatory* source document for an airway specifies the required VOR
> stations, among other things.
>
> The analogy is a VOR approach at PDQ Airport. You cannot fly that
> approach using ADF, for example.

Sam Spade
May 11th 06, 05:10 PM
Travis Marlatte wrote:
> As you say, part 95 governs IFR altitudes - not tracking airways. It does
> not define airways nor how to track them. It defines altitudes to be used
> when on and off airways.

I never said it governs tracking of airways. It does govern the ground
facilities you must use to track the airway; i.e., from "VOR ABC to VOR
DEF." Apparently, you don't understand that.
>
> Part 95 is irrelevant to the discussion at hand. There are no regulations
> that prohibit the use of a non-certified GPS in IFR flight.
>

That is your statement of opinion, which is not shared by everyone,
including those at the FAA who control this stuff.

Sam Spade
May 11th 06, 05:11 PM
Ron Lee wrote:

> Sam Spade > wrote:
>
>
wrote:
>>
>>>Ron Lee wrote:
>>>
>>>
>>>>Yes WAAS takes care of the integrity requirement.
>>>
>>>Even on a handheld like the Garmin 296/396 models?
>>>
>>
>>Because it is a VFR unit, you have no assurance that the method by which
>>the 296/396 employs WAAS provides the required integrity.
>>
>>Unless Garmin has a presence on this forum, no one can answer your
>>question with much of anything other than opinions.
>>
>>The folks are Garmin who engineer the aviation handhelds are part of the
>>same group that make GPS units for hikers, automobiles, etc; i.e. what
>>Garmin calls the "Consumer Products" group.
>>
>
> Thanks Sam. Hopefully one of my responses was not misleading. WAAS
> does make up for aviation integrity requirements that are not designed
> into current GPS satellites. But for IFR flight, it assumes the
> proper user equipment as well (I forget the applicable TSO).
>
> Ron Lee

145 and 146 I believe.

Steven P. McNicoll
May 11th 06, 07:43 PM
"Sam Spade" > wrote in message
news:OlJ8g.176145$bm6.85233@fed1read04...
>
> I never said it governs tracking of airways. It does govern the ground
> facilities you must use to track the airway; i.e., from "VOR ABC to VOR
> DEF." Apparently, you don't understand that.
>

Apparently you don't understand those ground facilities are also outside the
subject of discussion.


>
> That is your statement of opinion, which is not shared by everyone,
> including those at the FAA who control this stuff.
>

Saying there are no regulations that prohibit the use of a non-certified GPS
in IFR flight is a statement of fact, not of opinion. That there are some
in the FAA that don't understand that fact should surprise nobody.

Sam Spade
May 11th 06, 08:41 PM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:OlJ8g.176145$bm6.85233@fed1read04...
>
>>I never said it governs tracking of airways. It does govern the ground
>>facilities you must use to track the airway; i.e., from "VOR ABC to VOR
>>DEF." Apparently, you don't understand that.
>>
>
>
> Apparently you don't understand those ground facilities are also outside the
> subject of discussion.
>
>
>
>>That is your statement of opinion, which is not shared by everyone,
>>including those at the FAA who control this stuff.
>>
>
>
> Saying there are no regulations that prohibit the use of a non-certified GPS
> in IFR flight is a statement of fact, not of opinion. That there are some
> in the FAA that don't understand that fact should surprise nobody.
>
>
It is your opinion.

Steven P. McNicoll
May 11th 06, 08:53 PM
"Sam Spade" > wrote in message
news:hrM8g.176161$bm6.112176@fed1read04...
>
> It is your opinion.
>

Clearly you cannot differentiate fact from opinion.

Sam Spade
May 12th 06, 01:51 AM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:hrM8g.176161$bm6.112176@fed1read04...
>
>>It is your opinion.
>>
>
>
> Clearly you cannot differentiate fact from opinion.
>
>
Oh, I think it is you who cannot.

Do you have any experience with civil legal proceedings?

Such as,

findings of facts, and conclusions of law.

Clearly, your assertions of fact do not rise to the level of civil
adjudication by a court of compentent jurisdiction, although I will
never be able to convince you of that FACT.

Travis Marlatte
May 12th 06, 04:03 AM
Ok. We agree that Part 95 does not govern tracking airways.

It also does not govern the ground facitilities that must be used to track
airways. The only thing Part 95 does is refer to the airways and that is
only to allow the use of GPS in areas when it is impossible to use VORs to
track the airways.

I'm still missing the part where a regulation requires me to use a certified
GPS.

As a few examples of clarity, 91.181 requires that, during IFR flight, I fly
(a) on a airway or (b) a straight line to a fix. Note that it does not
stipulate the equipment I must use to accomplish that.

91.171 prohibits IFR navigation by reference to a VOR receiver unless it has
been checked.

91.205 requires that I have the appropriate equipment for the ground
facilities to be used.

The point that many people are trying to make in this discussion is that
there is no similarly explicit statement about using certified GPS receivers
for enroute navigation.

You have stated that this is only an opinion. Actually, it is not an
opinion. It is an observation that has yet to be refuted.

Please understand that I am only debating the explicit regulation to use
certified GPS receivers. It is fact only in that no one has been able to
cite a regulation to the contrary. You have stated an opinion that GPS
receivers must be certified for IFR enroute navigation but you have not
cited a regulation to back up that opinion.

--
-------------------------------
Travis
Lake N3094P
PWK


"Sam Spade" > wrote in message
news:OlJ8g.176145$bm6.85233@fed1read04...
> Travis Marlatte wrote:
>> As you say, part 95 governs IFR altitudes - not tracking airways. It does
>> not define airways nor how to track them. It defines altitudes to be used
>> when on and off airways.
>
> I never said it governs tracking of airways. It does govern the ground
> facilities you must use to track the airway; i.e., from "VOR ABC to VOR
> DEF." Apparently, you don't understand that.
>>
>> Part 95 is irrelevant to the discussion at hand. There are no regulations
>> that prohibit the use of a non-certified GPS in IFR flight.
>>
>
> That is your statement of opinion, which is not shared by everyone,
> including those at the FAA who control this stuff.

Steven P. McNicoll
May 12th 06, 04:32 AM
"Sam Spade" > wrote in message
news:z_Q8g.176186$bm6.58825@fed1read04...
>
> Oh, I think it is you who cannot.
>

I'm sure you do. You're wrong.

Sam Spade
May 12th 06, 10:13 AM
Steven P. McNicoll wrote:
> "Sam Spade" > wrote in message
> news:z_Q8g.176186$bm6.58825@fed1read04...
>
>>Oh, I think it is you who cannot.
>>
>
>
> I'm sure you do. You're wrong.
>
>
Interesting thast you chose to ignore the bulk of my post.

Sam Spade
May 12th 06, 10:21 AM
Travis Marlatte wrote:

> Ok. We agree that Part 95 does not govern tracking airways.
>
> It also does not govern the ground facitilities that must be used to track
> airways. The only thing Part 95 does is refer to the airways and that is
> only to allow the use of GPS in areas when it is impossible to use VORs to
> track the airways.

That is simply incorrect. Airways are described in great detail on
individual Forms 8260.16, which include the VOR stations, the IFR
altitudes, and the COPs. Each such amendment to an airway is an
amendment to Part 95, which is incorporated into the regulation through
the federal register by reference. This is virtually the same
rule-making procedure used to enact and amend instrument approach
procedures under Part 95.
>
> I'm still missing the part where a regulation requires me to use a certified
> GPS.
>
> As a few examples of clarity, 91.181 requires that, during IFR flight, I fly
> (a) on a airway or (b) a straight line to a fix. Note that it does not
> stipulate the equipment I must use to accomplish that.


>
> 91.171 prohibits IFR navigation by reference to a VOR receiver unless it has
> been checked.
>
> 91.205 requires that I have the appropriate equipment for the ground
> facilities to be used.

And, what constitutes a VOR (Victor) Airway.
>
> The point that many people are trying to make in this discussion is that
> there is no similarly explicit statement about using certified GPS receivers
> for enroute navigation.
>
> You have stated that this is only an opinion. Actually, it is not an
> opinion. It is an observation that has yet to be refuted.
>
> Please understand that I am only debating the explicit regulation to use
> certified GPS receivers. It is fact only in that no one has been able to
> cite a regulation to the contrary. You have stated an opinion that GPS
> receivers must be certified for IFR enroute navigation but you have not
> cited a regulation to back up that opinion.
>
It is a body of TSO, ACs, and FAA policy postions. The FAA would never
feel the need to issue a regulation that states VFR GPS cannot be used
for IFR navigation. They see no reason for it, since the body of
directives make it clear that only IFR certified avionics can be used
for IFR operations.

Dave Butler
May 12th 06, 02:22 PM
Sam Spade wrote:

> Airways are described in great detail on
> individual Forms 8260.16,

Are the forms 8260.16 available to the public somewhere?

Thanks,

Dave

karl gruber
May 12th 06, 04:46 PM
Google is your friend!

Damn, that's empowering to say!!

Karl
ATP CFI EC
"Curator" N185KG


"Dave Butler" > wrote in message
news:1147439954.376983@sj-nntpcache-5...
> Sam Spade wrote:
>
>> Airways are described in great detail on individual Forms 8260.16,
>
> Are the forms 8260.16 available to the public somewhere?
>
> Thanks,
>
> Dave

Dave Butler
May 12th 06, 06:40 PM
karl gruber wrote:
> Google is your friend!

Well, since apparently google is *your* friend and finding the 8260.16s is so
effortless for you, would you mind elaborating a little? OK, I'll admit to being
clueless, where are the 8260.16s (or at least, what search argument did you use
on your friend)?

> Damn, that's empowering to say!!

Glad I was able to brighten your day.

Dave

Tim Auckland
May 12th 06, 07:44 PM
There's a link to 8260.16 on:

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/policies_guidance/orders/

The actual link takes you to:

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/policies_guidance/orders/media/826016.pdf

which doesn't have anything about airways.

Tim.



On Fri, 12 May 2006 13:40:44 -0400, Dave Butler > wrote:

>karl gruber wrote:
>> Google is your friend!
>
>Well, since apparently google is *your* friend and finding the 8260.16s is so
>effortless for you, would you mind elaborating a little? OK, I'll admit to being
>clueless, where are the 8260.16s (or at least, what search argument did you use
>on your friend)?
>
>> Damn, that's empowering to say!!
>
>Glad I was able to brighten your day.
>
>Dave

Tim Auckland
May 12th 06, 08:28 PM
Don't you love the FAA.

TERPS forms are available through:

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/terps_forms/

which has a link 8260-16:

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/terps_forms/media/8260_16.pdf

which provides a blank 8260 - 16 form for specifiying airway data.

Seems that order 8260.16 has nothing to do with the 8260-16 form.

Still haven't found any populated 8260-16 forms on the web.

Cheers,

Tim.


On Fri, 12 May 2006 12:44:52 -0600, Tim Auckland > wrote:

>There's a link to 8260.16 on:
>
http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/policies_guidance/orders/
>
>The actual link takes you to:
>
http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs400/afs420/policies_guidance/orders/media/826016.pdf
>
>which doesn't have anything about airways.
>
>Tim.
>
>
>
>On Fri, 12 May 2006 13:40:44 -0400, Dave Butler > wrote:
>
>>karl gruber wrote:
>>> Google is your friend!
>>
>>Well, since apparently google is *your* friend and finding the 8260.16s is so
>>effortless for you, would you mind elaborating a little? OK, I'll admit to being
>>clueless, where are the 8260.16s (or at least, what search argument did you use
>>on your friend)?
>>
>>> Damn, that's empowering to say!!
>>
>>Glad I was able to brighten your day.
>>
>>Dave

Sam Spade
May 13th 06, 02:14 AM
Dave Butler wrote:
> Sam Spade wrote:
>
>> Airways are described in great detail on individual Forms 8260.16,
>
>
> Are the forms 8260.16 available to the public somewhere?
>
> Thanks,
>
> Dave
Not easily. Unlike instrument approach procedures, which are
coordinated with the aviation comunity, airways are considered by the
FAA to be "non-controversial," thus no public site during coordination.

The forms are maintained because they are "dockets" of prior rule-making.

Sam Spade
May 13th 06, 02:17 AM
Tim Auckland wrote:

>
>
> Still haven't found any populated 8260-16 forms on the web.

One of the appendices to Order 8260.19C, "Flight Procedures and
Airspace" has a sample comleted 8260-16.

May 13th 06, 09:49 AM
Bruce E. Haddad wrote:
> The following is from
> http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/83E208EBAEE3F233862569AF006ABA6B?OpenDocument
> (sorry for the long link). It's the GPS that's certified for IFR
> operations. As such - the regulations controlling pilots simply states that
> the equipment must be IFR certified. This circular starts to define the
> certification process. You can dig further into the science for more
> information.
> ...

AC 20-130A has come up already in response to my question. It presents
one way to install an IFR panel-mount GPS unit and get IFR approval for
it. But it says nothing about handhelds. I don't think you can
conclude that just because IFR approved installations exist that they
are required and necessary for all IFR operations.

You mentioned all sorts of stuff in you message about apporaches and
GPSs getting behind. I think all of the discussion here has only dealt
with enroute flying, not approaches.

GPS lag is also not the big deal you make it seem. Especially when
you're mostly traveling enroute in a straight line. Besides, most
modern GPSs have about a one second update rate. That's way faster
than the 12 second sweep of enroute radar and even faster than the 4.5
second sweep of approach radar. So you could make the same argument
about radar vectors.

And then you talk about errors in the GPS system. But all navaids have
errors. GPS is, in general, quite a bit more accurate than anything
but a localizer. Sure it can go bad, but all navaids have multiple
failure modes.

Peter

Sam Spade
May 13th 06, 02:42 PM
Dave Butler wrote:
> Sam Spade wrote:
>
>> Airways are described in great detail on individual Forms 8260.16,
>
>
> Are the forms 8260.16 available to the public somewhere?
>
> Thanks,
>
> Dave


Sample 8260-16 at:

http://members.cox.net/aterpster/

Travis Marlatte
May 13th 06, 07:55 PM
"Sam Spade" > wrote in message
news:wsY8g.176221$bm6.114875@fed1read04...

....

> That is simply incorrect. Airways are described in great detail on
> individual Forms 8260.16, which include the VOR stations, the IFR
> altitudes, and the COPs. Each such amendment to an airway is an amendment
> to Part 95, which is incorporated into the regulation through the federal
> register by reference. This is virtually the same rule-making procedure
> used to enact and amend instrument approach procedures under Part 95.

Agreed. Airways are well defined with procedures and regulations to ensure
that they are safe and flyable. None of that says anything at all about how
you must track those well defined airways.

Are we talking about the same Part 95? Why would Part 95 get ammended when
an airway is redefined? All I see is the definition of altitudes and
mountainous areas that apply to all defined airways.

....

>>
> It is a body of TSO, ACs, and FAA policy postions. The FAA would never
> feel the need to issue a regulation that states VFR GPS cannot be used for
> IFR navigation. They see no reason for it, since the body of directives
> make it clear that only IFR certified avionics can be used for IFR
> operations.

Keep in mind that we have been debating the lack of a regulation that
prohibits the use of GPS receivers that are not IFR certified for use during
enroute, IFR navigation.

I see nothing in what you have stated that "makes it clear" as a regulation.
I will agree that the FAA has created the mechanisms to use an IFR-certified
GPS for enroute navigation but it still has not said that that is the only
way to go.

-------------------------------
Travis
Lake N3094P
PWK

Travis Marlatte
May 13th 06, 08:03 PM
"Travis Marlatte" > wrote in message
...
> "Sam Spade" > wrote in message
> news:wsY8g.176221$bm6.114875@fed1read04...
>
....

>
> Are we talking about the same Part 95? Why would Part 95 get ammended when
> an airway is redefined? All I see is the definition of altitudes and
> mountainous areas that apply to all defined airways.

Never mind. I see the detailed references from Part 95 to specific airways.
All to define the altitudes to use. Nothing about tracking. I'm still
looking though. If you're right, I'm sure it's there somewhere...

Now where could it be? There must a statement that says something like, "No
person shall use a GPS receiver for IFR enroute navigation unless that
receiver is certified for enroute IFR under TSO..."

It must be there. I'll keep looking. If you find it, let me know.


-------------------------------
Travis
Lake N3094P
PWK

Mark Hansen
May 13th 06, 11:13 PM
On 05/13/06 12:03, Travis Marlatte wrote:
> "Travis Marlatte" > wrote in message
> ...
>> "Sam Spade" > wrote in message
>> news:wsY8g.176221$bm6.114875@fed1read04...
>>
> ...
>
>>
>> Are we talking about the same Part 95? Why would Part 95 get ammended when
>> an airway is redefined? All I see is the definition of altitudes and
>> mountainous areas that apply to all defined airways.
>
> Never mind. I see the detailed references from Part 95 to specific airways.
> All to define the altitudes to use. Nothing about tracking. I'm still
> looking though. If you're right, I'm sure it's there somewhere...
>
> Now where could it be? There must a statement that says something like, "No
> person shall use a GPS receiver for IFR enroute navigation unless that
> receiver is certified for enroute IFR under TSO..."
>
> It must be there. I'll keep looking. If you find it, let me know.

Yes, if you find it, let us all know.

--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

Sam Spade
May 14th 06, 12:20 AM
Travis Marlatte wrote:
> "Travis Marlatte" > wrote in message
> ...
>
>>"Sam Spade" > wrote in message
>>news:wsY8g.176221$bm6.114875@fed1read04...
>>
>
> ...
>
>
>>Are we talking about the same Part 95? Why would Part 95 get ammended when
>>an airway is redefined? All I see is the definition of altitudes and
>>mountainous areas that apply to all defined airways.
>
>
> Never mind. I see the detailed references from Part 95 to specific airways.
> All to define the altitudes to use. Nothing about tracking. I'm still
> looking though. If you're right, I'm sure it's there somewhere...
>
> Now where could it be? There must a statement that says something like, "No
> person shall use a GPS receiver for IFR enroute navigation unless that
> receiver is certified for enroute IFR under TSO..."
>
> It must be there. I'll keep looking. If you find it, let me know.

There is no regulation that defines tracking. That is a competency
standard issue. You demonstrate you can track an airway to at least
PTS, and you get an instrument rating (under an FAR, right?)

Part 95, in the case of Victor airways, tells you the VOR stations that
are required to navigate that airway.

Any subtitution for those VOR *ground* facilities are not your's to
decide; that discretion belongs to the FAA.

Travis Marlatte
May 14th 06, 04:15 PM
"Sam Spade" > wrote in message
news:VQt9g.176318$bm6.1157@fed1read04...
> There is no regulation that defines tracking. That is a competency
> standard issue. You demonstrate you can track an airway to at least PTS,
> and you get an instrument rating (under an FAR, right?)

Ah. Now I get it. That was the statement I needed to hear. Sorry for all the
unnecessary debate. It's a compentency issue. As long as I can track the
airway or direct within PTS, it doesn't matter how. Could be by physic
vision. Could be by IFR-certified GPS. Could be by a handheld GPS. Thanks
for clarifying.

>
> Part 95, in the case of Victor airways, tells you the VOR stations that
> are required to navigate that airway.
>
> Any subtitution for those VOR *ground* facilities are not your's to
> decide; that discretion belongs to the FAA.

Actually, Part 95 does nothing of the sort. It defines the airways in
reference to the VORs and defines them in a way such that someone tracking
them using a VOR is guaranteed radio reception.

The definition of the airway by reference to VORs has nothing to do with
tracking. I think that you agree that I can track an airway with an
IFR-certified GPS.

I agree that the FAA has defined most airways by reference to VORs. They
haven't stipulated that I must use a VOR receiver to track that airway. I
believe that there are now GPS fixes and airways defined by reference to
those fixes. I doubt that the FAA requires me to use a VOR receiver to track
those airways.

The debate is about tracking them or going direct (which has nothing to do
with airways at all) with a handheld.
--
-------------------------------
Travis
Lake N3094P
PWK

Sam Spade
May 14th 06, 04:55 PM
Travis Marlatte wrote:
> "Sam Spade" > wrote in message
> news:VQt9g.176318$bm6.1157@fed1read04...
>
>>There is no regulation that defines tracking. That is a competency
>>standard issue. You demonstrate you can track an airway to at least PTS,
>>and you get an instrument rating (under an FAR, right?)
>
>
> Ah. Now I get it. That was the statement I needed to hear. Sorry for all the
> unnecessary debate. It's a compentency issue. As long as I can track the
> airway or direct within PTS, it doesn't matter how. Could be by physic
> vision. Could be by IFR-certified GPS. Could be by a handheld GPS. Thanks
> for clarifying.
>
Not so. You are fixated on a fiction. If you tracked a Victor airway
on an instument rating ride with anything other than the *appropriate*
VOR it would be (or should be) a bust. Additionally, if you have an IFR
certified GPS installed, during the rating ride the examiner or
inspector could elect (in addition to tracking with VOR equipment) have
you demonstrate competency at loading into the database and tracking a
VOR airway using that IFR-certified GPS.

>
>>Part 95, in the case of Victor airways, tells you the VOR stations that
>>are required to navigate that airway.
>>
>>Any subtitution for those VOR *ground* facilities are not your's to
>>decide; that discretion belongs to the FAA.
>
>
> Actually, Part 95 does nothing of the sort. It defines the airways in
> reference to the VORs and defines them in a way such that someone tracking
> them using a VOR is guaranteed radio reception.

Part 95 has everything to do with definition of the airway. Reception
is only part of the mix.
>
> The definition of the airway by reference to VORs has nothing to do with
> tracking. I think that you agree that I can track an airway with an
> IFR-certified GPS.

Use of an IFR certified GPS for tracking of a Victor airway is
authorized by the FAA as a supplemental means of IFR navigation. You
must have the underlying VOR equipment installed and operable.
>
> I agree that the FAA has defined most airways by reference to VORs. They
> haven't stipulated that I must use a VOR receiver to track that airway. I
> believe that there are now GPS fixes and airways defined by reference to
> those fixes. I doubt that the FAA requires me to use a VOR receiver to track
> those airways.

Those are Q Routes, which are also issued under Part 95, thus the GPS
(or other approved RNAV) is the only method of tracking those routes.
But, because GPS is still not primary for non-radar navigation in this
country (with the limited Alaska exception) Q routes are thus far
developed only where centers have radar coverage for surveillance of the
Q routes.
>
> The debate is about tracking them or going direct (which has nothing to do
> with airways at all) with a handheld.

It has everything to do with airways if your clearance is via an airway.

Steven P. McNicoll
May 16th 06, 11:22 PM
"Sam Spade" > wrote in message
news:wsY8g.176221$bm6.114875@fed1read04...
>>
>> I'm still missing the part where a regulation requires me to use a
>> certified GPS.
>>
>> As a few examples of clarity, 91.181 requires that, during IFR flight, I
>> fly (a) on a airway or (b) a straight line to a fix. Note that it does
>> not stipulate the equipment I must use to accomplish that.
>
>
>>
>> 91.171 prohibits IFR navigation by reference to a VOR receiver unless it
>> has been checked.
>>
>> 91.205 requires that I have the appropriate equipment for the ground
>> facilities to be used.
>
> And, what constitutes a VOR (Victor) Airway.
>

FARs 91.171, 91.181, and 91.205 say nothing about what constitutes a VOR
airway.


>
>> The point that many people are trying to make in this discussion is that
>> there is no similarly explicit statement about using certified GPS
>> receivers for enroute navigation.
>>
>> You have stated that this is only an opinion. Actually, it is not an
>> opinion. It is an observation that has yet to be refuted.
>>
>> Please understand that I am only debating the explicit regulation to use
>> certified GPS receivers. It is fact only in that no one has been able to
>> cite a regulation to the contrary. You have stated an opinion that GPS
>> receivers must be certified for IFR enroute navigation but you have not
>> cited a regulation to back up that opinion.
>>
>
> It is a body of TSO, ACs, and FAA policy postions.
>

Do you mean like this statement from AC No. 00-2.15; "The FAA issues
advisory circulars to inform the aviation public in a systematic way of
non-regulatory material. Unless
incorporated into a regulation by reference, the contents of an advisory
circular are not binding on the public." Does that not state an FAA policy
position?

Or this statement from AC 20-130A; "Like all advisory material, this AC is
not mandatory and does not constitute a requirement." Does that not state
an FAA policy position?

Or this statement from AC 20-138A; "This advisory circular (AC) provides
guidance material for the airworthiness approval of Global Navigation
Satellite System (GNSS) equipment. Like all AC material, this AC is not
mandatory and does not constitute a regulation." Does that not state an FAA
policy position?

Or this statement from the AIM; "The FAA publishes the Code of Federal
Regulations (CFRs) to make readily available to the aviation community the
regulatory requirements placed upon them." Does that not state an FAA
policy position?


>
> The FAA would never
> feel the need to issue a regulation that states VFR GPS cannot be used for
> IFR navigation.
>

You finally got something right! I guess the old blind squirrel adage has
some truth in it. You're right that the FAA would not issue a regulation
that states what cannot be used, they'd issue an FAR that states what must
be used. Like FARs 91.215 and 91.217, which require transponders and
encoders that meet the requirements of TSOs C74, C112, C10, or C88.


>
> They see no reason for it, since the body of directives
> make it clear that only IFR certified avionics can be used for IFR
> operations.
>

There is no body of directives like that. What caused you to believe there
was?

Steven P. McNicoll
May 16th 06, 11:39 PM
"Sam Spade" > wrote in message
news:rpI9g.176355$bm6.115303@fed1read04...
>
> Not so. You are fixated on a fiction. If you tracked a Victor airway on
> an instument rating ride with anything other than the *appropriate* VOR it
> would be (or should be) a bust.
>

What do you base that statement on? Airways can be assigned even when the
VORs defining them are out of service as long as the aircraft is /E, /F, /G,
or /R.

Steven P. McNicoll
May 17th 06, 12:13 AM
"Bruce E. Haddad" > wrote in message
...
>
> The following is from
> http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/83E208EBAEE3F233862569AF006ABA6B?OpenDocument
> (sorry for the long link).
>

All I get is "The page cannot be displayed".


>
> It's the GPS that's certified for IFR
> operations. As such - the regulations controlling pilots simply states
> that the equipment must be IFR certified.
>

What FAR states that?


>
> Remember - the GPS will never show where you are.
>

Really? Where am I when the GPS says I'm motionless on the ramp?


>
> It will only show where
> you WERE. How far behind you the GPS is can be problematic. Each GPS
> receiver has it's own formula for choosing satellites from the visible
> part of the constellation. Each of the satellites have errors (not the
> induced errors - just such errors as drift in the constellation, signal
> degradation due to atmospheric interference, etc.). A lot of things need
> to be engineered into the GPS to make it reliable enough for me to trust
> it for approaches.
>

Do you trust ADF or NDB enough for approaches?

Sam Spade
May 17th 06, 10:55 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:rpI9g.176355$bm6.115303@fed1read04...
>
>>Not so. You are fixated on a fiction. If you tracked a Victor airway on
>>an instument rating ride with anything other than the *appropriate* VOR it
>>would be (or should be) a bust.
>>
>
>
> What do you base that statement on? Airways can be assigned even when the
> VORs defining them are out of service as long as the aircraft is /E, /F, /G,
> or /R.
>
>
Sure they can with an IFR certifed GPS. But, on a instrument rating
ride the examiner or inspector doing a proper check ride would avoid an
airway that cannot be flown with VOR equipment for the portion of the
check ride that involves testing the applicant's competency in flying a
VOR airway with VOR equipment.

Also, the rating ride can still be conducted in an aircraft without IFR
GPS equipment but it cannot be conducted in an aircraft without VOR
equipment.

I think you are confusing normal operations with a GPS equipped aircraft
with an instrument rating ride.

Sam Spade
May 17th 06, 11:01 AM
Steven P. McNicoll wrote:

> "Sam Spade" > wrote in message
> news:wsY8g.176221$bm6.114875@fed1read04...
>
>>>I'm still missing the part where a regulation requires me to use a
>>>certified GPS.
>>>
>>>As a few examples of clarity, 91.181 requires that, during IFR flight, I
>>>fly (a) on a airway or (b) a straight line to a fix. Note that it does
>>>not stipulate the equipment I must use to accomplish that.
>>
>>
>>>91.171 prohibits IFR navigation by reference to a VOR receiver unless it
>>>has been checked.
>>>
>>>91.205 requires that I have the appropriate equipment for the ground
>>>facilities to be used.
>>
>>And, what constitutes a VOR (Victor) Airway.
>>
>
>
> FARs 91.171, 91.181, and 91.205 say nothing about what constitutes a VOR
> airway.
>
No, the particular Part 95 amendment for a given airway sets forth what
constitutes an airway. How many times to I have to state this so you
get something right, eventually?
>
>
>>>The point that many people are trying to make in this discussion is that
>>>there is no similarly explicit statement about using certified GPS
>>>receivers for enroute navigation.
>>>
>>>You have stated that this is only an opinion. Actually, it is not an
>>>opinion. It is an observation that has yet to be refuted.
>>>
>>>Please understand that I am only debating the explicit regulation to use
>>>certified GPS receivers. It is fact only in that no one has been able to
>>>cite a regulation to the contrary. You have stated an opinion that GPS
>>>receivers must be certified for IFR enroute navigation but you have not
>>>cited a regulation to back up that opinion.
>>>
>>
>>It is a body of TSO, ACs, and FAA policy postions.
>>
>
>
> Do you mean like this statement from AC No. 00-2.15; "The FAA issues
> advisory circulars to inform the aviation public in a systematic way of
> non-regulatory material. Unless
> incorporated into a regulation by reference, the contents of an advisory
> circular are not binding on the public." Does that not state an FAA policy
> position?
>
> Or this statement from AC 20-130A; "Like all advisory material, this AC is
> not mandatory and does not constitute a requirement." Does that not state
> an FAA policy position?
>
> Or this statement from AC 20-138A; "This advisory circular (AC) provides
> guidance material for the airworthiness approval of Global Navigation
> Satellite System (GNSS) equipment. Like all AC material, this AC is not
> mandatory and does not constitute a regulation." Does that not state an FAA
> policy position?
>
> Or this statement from the AIM; "The FAA publishes the Code of Federal
> Regulations (CFRs) to make readily available to the aviation community the
> regulatory requirements placed upon them." Does that not state an FAA
> policy position?
>
>
>
>>The FAA would never
>>feel the need to issue a regulation that states VFR GPS cannot be used for
>>IFR navigation.
>>
>
>
> You finally got something right! I guess the old blind squirrel adage has
> some truth in it. You're right that the FAA would not issue a regulation
> that states what cannot be used, they'd issue an FAR that states what must
> be used. Like FARs 91.215 and 91.217, which require transponders and
> encoders that meet the requirements of TSOs C74, C112, C10, or C88.
>

You just love to muddy the waters. The FAA has determined what
consitutes IFR GPS equipment. Unlike transponders, which everyone must
have, there is no requirement to have IFR GPS equipment to operate in
the IFR system, thus no need to tie the TSOs to a regulation, unlike
transponders.
>
>
>>They see no reason for it, since the body of directives
>>make it clear that only IFR certified avionics can be used for IFR
>>operations.
>>
>
>
> There is no body of directives like that. What caused you to believe there
> was?
>
>
Various ARINC directives. TSO C-129, 145, and 146. You think those are
advisory, AFS and AIR do not. They manage these programs in the FAA,
you do not.

Steven P. McNicoll
May 17th 06, 03:34 PM
Sam Spade wrote:
>
> No, the particular Part 95 amendment for a given airway sets forth what
> constitutes an airway.
>

FARs 91.171, 91.181, and 91.205 are not found in Part 95.


>
> How many times to I have to state this so you get something right, eventually?
>

It doesn't matter, it's wrong every time you state it.


>
> You just love to muddy the waters.
>

Not at all, my sole purpose here is to clarify the waters. What is
your purpose here?


>
> The FAA has determined what
> consitutes IFR GPS equipment. Unlike transponders, which everyone must
> have, there is no requirement to have IFR GPS equipment to operate in
> the IFR system, thus no need to tie the TSOs to a regulation, unlike
> transponders.
>

But not everyone is required to have transponders.


>
> Various ARINC directives. TSO C-129, 145, and 146.
>

None of those make it clear that only IFR certified avionics can be
used for IFR operations. What caused you to believe they did?


>
> You think those are
> advisory, AFS and AIR do not. They manage these programs in the FAA,
> you do not.
>

It has been demonstrated that they are only advisory, it matters not
what AFS and AIR think. What led you to believe differently?

Travis Marlatte
May 18th 06, 12:54 PM
"Sam Spade" > wrote in message
news:%pCag.177125$bm6.142153@fed1read04...
> Sure they can with an IFR certifed GPS. But, on a instrument rating ride
> the examiner or inspector doing a proper check ride would avoid an airway
> that cannot be flown with VOR equipment for the portion of the check ride
> that involves testing the applicant's competency in flying a VOR airway
> with VOR equipment.


Just because an examiner might want to see a VOR used to track an airway
doesn't imply that that is the only legal way to do so.

Just because an airway might be defined in reference to VORs to ensure that
they are trackable by using a VOR doesn't imply that that is the only way to
do so.

Just because there are official FAA documents that describe how to certify a
GPS receiver for IFR flight doesn't imply that that is required for IFR
flight.

You've gone off on several lines of reasoning that have led to nowhere.

Sam, it might very well be an oversight that there is no regulation
requiring IFR-certified GPS. It might very well be the intent of the FAA
that such a thing is required. They may change that in the future.

All this debate and all of your non-regulatory examples has convinced me
even more that no such regulation exists.
--
-------------------------------
Travis
Lake N3094P
PWK

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