More IFR with VFR GPS questions

[Chris Quaintance]

Hi Folks-

Without descending into the madness of the other thread, I have a
couple of questions regarding the use of a VFR GPS while IFR.

Hypothetically, let's say I was flying IFR from Santa Monica, CA to San
Jose, CA (SMO to RHV). The weather is CAVU. I am filed /A and cleared
via a fairly standard route on victor airways. Just past the mountains
and still >150 miles from RHV, Oakland Center asks me if I am "GPS
equipped." I answer in the affirmative as I have my trusty Garmin 296
mounted on the yoke. I am then cleared direct GILRO, direct RHV and I
accept the clearance. I proceed to fly said clearance and land at my
destination without futher issue.

I realize this is common practice. It seems to me it would not be
strictly "legal" as I would be relying on the 296 for primary
navigation.

My questions:
--Where did this situation actually break down in terms of regulations?
When I affirmed I was GPS equipped (knowing that mine is not
certified)? When I accepted the new clearance? Never?
--In CAVU weather, the risk of this becoming a problem is basically
nil. However, in IMC, I would consider it to be potentially
problematic (i.e. the 296 goes Tango Uniform and I'm not exactly sure
of my position using my trusty VOR's). Would you consider this risk
neglible? Would you accept or not accept this clearance depending on
the weather? And why?

Thanks for your thoughts.

Cheers,
--Chris

[Newps]

Chris Quaintance wrote:
> Hi Folks-
>
> Without descending into the madness of the other thread, I have a
> couple of questions regarding the use of a VFR GPS while IFR.
>
> Hypothetically, let's say I was flying IFR from Santa Monica, CA to San
> Jose, CA (SMO to RHV). The weather is CAVU.

The wx is irrelavant.



I am filed /A and cleared
> via a fairly standard route on victor airways. Just past the mountains
> and still >150 miles from RHV, Oakland Center asks me if I am "GPS
> equipped." I answer in the affirmative as I have my trusty Garmin 296
> mounted on the yoke. I am then cleared direct GILRO, direct RHV and I
> accept the clearance. I proceed to fly said clearance and land at my
> destination without futher issue.
>
> I realize this is common practice. It seems to me it would not be
> strictly "legal" as I would be relying on the 296 for primary
> navigation.

That's because it isn't legal. To be legal you have to be on a vector,
direct when able.


>
> My questions:
> --Where did this situation actually break down in terms of regulations?

When you accepted a direct clearance that you can't fly without the GPS.



> --In CAVU weather, the risk of this becoming a problem is basically
> nil. However, in IMC, I would consider it to be potentially
> problematic (i.e. the 296 goes Tango Uniform and I'm not exactly sure
> of my position using my trusty VOR's).

Right, good weather only makes you feel better, doesn't affect the legality.


Would you consider this risk
> neglible?

Yes.

[Steven P. McNicoll]

"Newps" > wrote in message
. ..
>
> That's because it isn't legal.

What law is being violated?


>
> To be legal you have to be on a vector, direct when able.
>

In what law is that requirement found?

[Dave Butler]

Chris Quaintance wrote:
> Hi Folks-
>
> Without descending into the madness of the other thread, I have a
> couple of questions regarding the use of a VFR GPS while IFR.

In what way is your premise or your questions different from "the other thread"?

<snip>

> My questions:
> --Where did this situation actually break down in terms of regulations?
> When I affirmed I was GPS equipped (knowing that mine is not
> certified)? When I accepted the new clearance? Never?

Never, IMO... but we just descended into "the madness of the other thread."

> --In CAVU weather, the risk of this becoming a problem is basically
> nil. However, in IMC, I would consider it to be potentially
> problematic (i.e. the 296 goes Tango Uniform and I'm not exactly sure
> of my position using my trusty VOR's). Would you consider this risk
> neglible? Would you accept or not accept this clearance depending on
> the weather? And why?

Risk negligible, would accept without reference to the weather.

[Bob Noel]

In article om>,
"Chris Quaintance" > wrote:

> Hi Folks-
>
> Without descending into the madness of the other thread, I have a
> couple of questions regarding the use of a VFR GPS while IFR.
>
> Hypothetically, let's say I was flying IFR from Santa Monica, CA to San
> Jose, CA (SMO to RHV). The weather is CAVU. I am filed /A and cleared
> via a fairly standard route on victor airways. Just past the mountains
> and still >150 miles from RHV, Oakland Center asks me if I am "GPS
> equipped." I answer in the affirmative as I have my trusty Garmin 296
> mounted on the yoke. I am then cleared direct GILRO, direct RHV and I
> accept the clearance. I proceed to fly said clearance and land at my
> destination without futher issue.
>
> I realize this is common practice. It seems to me it would not be
> strictly "legal" as I would be relying on the 296 for primary
> navigation.

It is my understanding that you will only get a direct off-airway clearance
if you are in radar coverage. In that case (being in radar coverage), having
a VFR GPS handheld or the fanciest IFR-certified GPS installation imaginable
doesn't make any difference in the legality of accepting the clearance.

--
Bob Noel
New NHL? what a joke

[Chris Quaintance]

Dave Butler wrote:
> In what way is your premise or your questions different from "the other thread"?

The other thread was started questioning the wisdom of filing with "VFR
GPS" in the remarks section of one's flight plan. I was hoping to
focus on the mechanics of accepting a direct clearance that one could
not otherwise navigate without a VFR GPS. I'd like to have a better
idea of the legality and (more importantly) the advisability of flying
in that situation.

Oh, and I would also like to avoid the personal attacks, one-liners,
and general McNicoll-like flavor of the other thread, but that may
prove to be impossible.

Cheers,
--Chris

[A Lieberman]

On 21 Nov 2005 16:52:51 -0800, Chris Quaintance wrote:
> I was hoping to
> focus on the mechanics of accepting a direct clearance that one could
> not otherwise navigate without a VFR GPS. I'd like to have a better
> idea of the legality and (more importantly) the advisability of flying
> in that situation.

Chris,

Speaking from my recent IFR experiences....

I had filed direct from 2G2 to KBWG. I got a call from Center saying
Sundownwer 1943L, have a reroute for you, ready to copy. Got my trusty pen
out, said ready to copy. I was in solid IMC. Center said, cleared direct
York VOR, direct BWG.

I filed /A so they apparently knew I could not fly a GPS route. Had they
routed me to something other then a standard VOR or intersection, I would
have said unable.

I had my enroute maps out, and when I was not able to find the York VOR, I
keyed up and asked for the frequency. Dialed that in, got my radial and
started flying to it. I wasn't able to determine the distance, I keyed up
again and asked the distance, since it was not registering on my DME or was
in the nrst navaids on my Garmin 296.

Turned out, ATC had me heading to a VOR 90 miles away!

I figured as long as I remained above the OROCA and had my enroute maps
out, that I am legal, since I am able to fly to a navaid my plane was IFR
certified for.

So, in a nutshell, not a big deal providing you are above OROCA and fully
situational aware of your navaid surroundings.

Allen

[Newps]

Bob Noel wrote:


>
>
> It is my understanding that you will only get a direct off-airway clearance
> if you are in radar coverage.


The rule says you also have to be out of the service volume of the
navaid. This is routinely ignored.

[Newps]

Chris Quaintance wrote:

> Dave Butler wrote:
>
>>In what way is your premise or your questions different from "the other thread"?
>
>
> The other thread was started questioning the wisdom of filing with "VFR
> GPS" in the remarks section of one's flight plan. I was hoping to
> focus on the mechanics of accepting a direct clearance that one could
> not otherwise navigate without a VFR GPS. I'd like to have a better
> idea of the legality and (more importantly) the advisability of flying
> in that situation.

Have you asked this question to FSDO?

[Newps]

A Lieberman wrote:


>
> Turned out, ATC had me heading to a VOR 90 miles away!

90 miles doesn't require a GPS, although it makes it easier to fly.


>
> I figured as long as I remained above the OROCA and had my enroute maps
> out, that I am legal,

On a direct clearance like that ATC is responsible for terrain
seperation so you wouldn't have got that clearance unless you were above
the MVA/MIA.

[S Herman]

On 21 Nov 2005 16:52:51 -0800, "Chris Quaintance"
> wrote:

> I was hoping to
>focus on the mechanics of accepting a direct clearance that one could
>not otherwise navigate without a VFR GPS. I'd like to have a better
>idea of the legality and (more importantly) the advisability of flying
>in that situation.

First off I am an instrument student, not yet rated. I have a lot more
marine navigation experience than aviation IFR experience, but let me
throw this out.
It seems possible to me to fly direct between most any 2 points, off
airways, without vectors, using 2 VOR's and a sectional chart. Just
plot a series of radial intersections at appropriate distances from
each other to ensure remaining close (for gov'ment work) to the
desired direct track. Is this illegal? Or is it just that you won't
get a clearance using this method? I am assuming that the direct
course & altitude would be within reception range of the (2) needed
stations.
This would require a bit of OBS twisting for sure. You would use your
VFR GPS to reassure yourself that you are on that desired track. If
anyone asks, your primary means of navigating were by use of VOR's.

[Jose]

> It seems possible to me to fly direct between most any 2 points, off
> airways, without vectors, using 2 VOR's and a sectional chart. Just
> plot a series of radial intersections at appropriate distances from
> each other to ensure remaining close (for gov'ment work) to the
> desired direct track.

I don't know if it is legal or not (that would be up to the FAA, after
the accident), but it would be impractical. I have almost never flown
an IFR clearance that I have carefully plotted at home. The clearance I
get is different, and there are numerous reroutes enroute. Imagine
being in bumpy air in the soup, and given "direct WAYNS". You are
somewhere between two VORs flying an airway. Ok, with an intersection
you can figure out pretty much where you are, now try plotting it on
your lap on a sectional, crossing from front to back, going over three
creases, bumping along in the clouds. Betcha can't even draw a straight
line, let alone calculate points along it.

Jose
--
He who laughs, lasts.
for Email, make the obvious change in the address.

[Roger]

On Wed, 23 Nov 2005 00:14:38 GMT, Jose >
wrote:

>> It seems possible to me to fly direct between most any 2 points, off
>> airways, without vectors, using 2 VOR's and a sectional chart. Just
>> plot a series of radial intersections at appropriate distances from
>> each other to ensure remaining close (for gov'ment work) to the
>> desired direct track.
>
>I don't know if it is legal or not (that would be up to the FAA, after
>the accident), but it would be impractical. I have almost never flown
>an IFR clearance that I have carefully plotted at home. The clearance I
>get is different, and there are numerous reroutes enroute. Imagine
>being in bumpy air in the soup, and given "direct WAYNS". You are
>somewhere between two VORs flying an airway. Ok, with an intersection
>you can figure out pretty much where you are, now try plotting it on
>your lap on a sectional, crossing from front to back, going over three
>creases, bumping along in the clouds. Betcha can't even draw a straight
>line, let alone calculate points along it.

The last time I plotted a course was for the PPL. I didn't even have
to plot one for the instrument rating. I did have a chart with my
times (from the computer) and I was carrying a simple calculator.
I used a VFR hand held GPS for "situational awareness" and that made
the DE happy.

BTW, my hand held has all the enroute way points in it.
The latest update even has the fixes for the local GPS approaches.


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

[Steven P. McNicoll]

"Chris Quaintance" > wrote in message
ups.com...
>
> Without descending into the madness of the other thread, I have a
> couple of questions regarding the use of a VFR GPS while IFR.
>
> Hypothetically, let's say I was flying IFR from Santa Monica, CA to San
> Jose, CA (SMO to RHV). The weather is CAVU. I am filed /A and cleared
> via a fairly standard route on victor airways. Just past the mountains
> and still >150 miles from RHV, Oakland Center asks me if I am "GPS
> equipped." I answer in the affirmative as I have my trusty Garmin 296
> mounted on the yoke. I am then cleared direct GILRO, direct RHV and I
> accept the clearance. I proceed to fly said clearance and land at my
> destination without futher issue.
>
> I realize this is common practice. It seems to me it would not be
> strictly "legal" as I would be relying on the 296 for primary
> navigation.
>
> My questions:
> --Where did this situation actually break down in terms of regulations?
>

It didn't, no regulation is violated in your scenario.


>
> When I affirmed I was GPS equipped (knowing that mine is not
> certified)?
>

No regulation requires a "certified" GPS for the operation you described.


>
> When I accepted the new clearance? Never?
>

Never.


>
> --In CAVU weather, the risk of this becoming a problem is basically
> nil. However, in IMC, I would consider it to be potentially
> problematic (i.e. the 296 goes Tango Uniform and I'm not exactly sure
> of my position using my trusty VOR's). Would you consider this risk
> neglible? Would you accept or not accept this clearance depending on
> the weather? And why?
>

What would you do in that same situation if your GPS was certified? A
certified GPS that has gone TU is no more useful than a non-certified GPS
that has gone TU.

Weather changes nothing. The operation you described can only be done if
ATC can provide radar monitoring and radar monitoring must be provided even
if your GPS is certified for IFR.

[Steven P. McNicoll]

"A Lieberman" > wrote in message
...
>
> Speaking from my recent IFR experiences....
>
> I had filed direct from 2G2 to KBWG. I got a call from Center saying
> Sundownwer 1943L, have a reroute for you, ready to copy. Got my trusty
> pen out, said ready to copy. I was in solid IMC. Center said, cleared
> direct
> York VOR, direct BWG.
>
> I filed /A so they apparently knew I could not fly a GPS route. Had they
> routed me to something other then a standard VOR or intersection, I would
> have said unable.
>

You had originally filed direct from one airport to another one 337 miles
away. How did you intend to do that if you were unable to accept a reroute
to something other than a standard VOR or intersection?


>
> I had my enroute maps out, and when I was not able to find the York VOR, I
> keyed up and asked for the frequency. Dialed that in, got my radial and
> started flying to it. I wasn't able to determine the distance, I keyed up
> again and asked the distance, since it was not registering on my DME or
> was in the nrst navaids on my Garmin 296.
>
> Turned out, ATC had me heading to a VOR 90 miles away!
>

YRK vortac is 148 miles southwest of 2G2. Do you believe there's something
wrong with being routed over a VOR that far away?

[Steven P. McNicoll]

"Newps" > wrote in message
...
>>
>> It is my understanding that you will only get a direct off-airway
>> clearance
>> if you are in radar coverage.
>>
>
> The rule says you also have to be out of the service volume of the navaid.
> This is routinely ignored.
>

No rule says you have to be out of the service volume in order to get a
direct off-airway clearance.

[A Lieberman]

On Wed, 23 Nov 2005 15:07:14 GMT, Steven P. McNicoll wrote:

> You had originally filed direct from one airport to another one 337 miles
> away. How did you intend to do that if you were unable to accept a reroute
> to something other than a standard VOR or intersection?

Precisely my point Steve.

Even though I filed direct, off airwaves, ATC recognized my limitation that
I could only accept a standard VOR or intersection. It was NOT assumed by
ATC that I had GPS capability even though I filed direct.

Had they given me a GPS intersection rather then a VOR or VOR associated
intersection, I would have said unable, alerting them to the fact I am
slant Alpha. That was the point I was trying to bring across in my
original post.

This was my first reroute in my short flying career, and overall, in spite
of my uncertainty in the first few minutes, it turned out to be a non
event.

> YRK vortac is 148 miles southwest of 2G2. Do you believe there's something
> wrong with being routed over a VOR that far away?

Considering there are quite a few VORs closer then YRK, I was not looking
that far down the road in establishing where I am to where I am going. I
was looking within 45 to 60 miles, not so far down the road.

I am situationally aware of what my next VOR will be when I fly IFR, as I
have them printed as well having the en route maps open. I also change my
NAV 1 and NAV 2 as I progress in my flight path to assist in my situation
awareness.

The problem I had as slight as it was, was finding the frequency to the
VOR. Wasn't in the list of nrst on my Garmin 296, and being in IMC, it's
not exactly conducive of finding a navaid on the paper maps especially 90
odd miles away. I wasn't given a vector, just direct York, direct Bowling
green, so I did not know what direction to look on the en route maps. Had
center given me a vector, I at least would have known which direction to
look.

I would have expected a closer VOR, not one 90 miles away to go direct to.
As you can see, not that big a deal, but for a person like me, learning the
ropes of IFR, when I am by myself, I don't have CRM available. Small
things do make a big difference.

So, like I said in my original post, I spoke up and asked the questions I
needed answered to make my flight safer.

No big deal in the full scheme of things, but since this was my first
reroute, it does make the heart go a little faster as I don't want to do
the wrong thing. All the training in the world does not give you the real
world scenarios.

Allen

[Peter R.]

A Lieberman > wrote:

> All the training in the world does not give you the real
> world scenarios.

All the training in the world does not give you *all* the real world
scenarios. It certainly gives you some. ;-)

--
Peter

[Steven P. McNicoll]

"Newps" > wrote in message
...
>
> Have you asked this question to FSDO?
>

I did. About six years ago 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".

[A Lieberman]

On Tue, 22 Nov 2005 08:06:39 -0700, Newps wrote:

>> Turned out, ATC had me heading to a VOR 90 miles away!
>
> 90 miles doesn't require a GPS, although it makes it easier to fly.

Your right Newps. I was only trying to use the GPS to figure the distant
and time as my DME didn't pickup York VOR until I was about 60 some odd
miles away.

I wanted to evaluate my fuel situation and see how far off course this
reroute would take me. I already was going to be in the air 4 hours based
on a direct routing, so the reroute could have caused me to start
considering a fuel stop b4 Bowling Green.

To be honest, tracking a VOR or flying a GPS track really isn't that much
different when you look at the whole scheme of things.

Just a little less variation with GPS, sorta like comparing the DG to the
wet compass. DG makes it easier, but tracking a straight line, wet compass
does just as well with a little variation.

Allen

[A Lieberman]

On Wed, 23 Nov 2005 10:34:24 -0500, Peter R. wrote:

> A Lieberman > wrote:
>
>> All the training in the world does not give you the real
>> world scenarios.
>
> All the training in the world does not give you *all* the real world
> scenarios. It certainly gives you some. ;-)

Thanks for clarifying what I meant Peter :-)

Though when I think about it, my VFR training required a diversion to
another airport. My IFR training did not require it. Wonder why that is?

Both scenarios play out the same, finding the airport and navigating to
it.....

Maybe something to consider for future IFR students?

Allen

[Steven P. McNicoll]

"A Lieberman" > wrote in message
...
> On Wed, 23 Nov 2005 15:07:14 GMT, Steven P. McNicoll wrote:
>>
>> You had originally filed direct from one airport to another one 337 miles
>> away. How did you intend to do that if you were unable to accept a
>> reroute
>> to something other than a standard VOR or intersection?
>>
>
> Precisely my point Steve.
>

???


>
> Even though I filed direct, off airwaves, ATC recognized my limitation
> that
> I could only accept a standard VOR or intersection.
>

Surely you could accept an airway? What else would you expect ATC use for a
reroute, other than VORs, intersections and airways?


>
> It was NOT assumed by
> ATC that I had GPS capability even though I filed direct.
>

I think it likely that ATC did assume you had GPS capability precisely
because you filed direct. They have to assume that you have the capability
to fly what you filed and at this time it is GPS that is most likely to give
you that capability.


>
> Had they given me a GPS intersection rather then a VOR or VOR associated
> intersection, I would have said unable, alerting them to the fact I am
> slant Alpha. That was the point I was trying to bring across in my
> original post.
>

What is a "GPS intersection"?


>>
>> YRK vortac is 148 miles southwest of 2G2. Do you believe there's
>> something
>> wrong with being routed over a VOR that far away?
>>
>
> Considering there are quite a few VORs closer then YRK, I was not looking
> that far down the road in establishing where I am to where I am going. I
> was looking within 45 to 60 miles, not so far down the road.
>
> I am situationally aware of what my next VOR will be when I fly IFR, as I
> have them printed as well having the en route maps open. I also change my
> NAV 1 and NAV 2 as I progress in my flight path to assist in my situation
> awareness.
>
> The problem I had as slight as it was, was finding the frequency to the
> VOR. Wasn't in the list of nrst on my Garmin 296, and being in IMC, it's
> not exactly conducive of finding a navaid on the paper maps especially 90
> odd miles away. I wasn't given a vector, just direct York, direct Bowling
> green, so I did not know what direction to look on the en route maps. Had
> center given me a vector, I at least would have known which direction to
> look.
>
> I would have expected a closer VOR, not one 90 miles away to go direct to.
> As you can see, not that big a deal, but for a person like me, learning
> the
> ropes of IFR, when I am by myself, I don't have CRM available. Small
> things do make a big difference.
>

Did you examine your chosen route at all when you were planning your trip?
Almost halfway between 2G2 and BWG lie a couple of MOAs, your filed route
goes through them. Just a few miles south of the MOAs is York VOR. Your
reroute was probably necessary because the MOAs were in use.

[Steven P. McNicoll]

"S Herman" > wrote in message
...
>
> First off I am an instrument student, not yet rated. I have a lot more
> marine navigation experience than aviation IFR experience, but let me
> throw this out.
> It seems possible to me to fly direct between most any 2 points, off
> airways, without vectors, using 2 VOR's and a sectional chart. Just
> plot a series of radial intersections at appropriate distances from
> each other to ensure remaining close (for gov'ment work) to the
> desired direct track. Is this illegal?
>

No.


>
> Or is it just that you won't get a clearance using this method?
>

You can get a clearance using that method. ATC cannot know what you're
using for navigation unless you tell them and there's no reason for them to
ask.


>
> I am assuming that the direct
> course & altitude would be within reception range of the (2) needed
> stations.
>

Then what's the point of plotting a series of radial intersections at
appropriate distances from each other to ensure remaining close to the
desired track? The desired track would be the two radials that define a
direct course between the two VORs.


>
> This would require a bit of OBS twisting for sure.
>

It would require you to select the outbound radial from the first VOR and
the inbound radial from the second VOR.


>
> You would use your VFR GPS to reassure yourself that you are on that
> desired track. If anyone asks, your primary means of navigating were by
> use of VOR's.
>

If you have a VFR GPS why bother with a course between two VORs?

[Steven P. McNicoll]

"Jose" > wrote in message
m...
>
> I don't know if it is legal or not (that would be up to the FAA, after the
> accident), but it would be impractical. I have almost never flown an IFR
> clearance that I have carefully plotted at home. The clearance I get is
> different, and there are numerous reroutes enroute. Imagine being in
> bumpy air in the soup, and given "direct WAYNS". You are somewhere
> between two VORs flying an airway. Ok, with an intersection you can
> figure out pretty much where you are, now try plotting it on your lap on a
> sectional, crossing from front to back, going over three creases, bumping
> along in the clouds. Betcha can't even draw a straight line, let alone
> calculate points along it.
>

If you filed via airways and with an equipment suffix that does not indicate
any RNAV capability you should not be told to proceed direct to an
intersection. If you are just respond "Unable."

[Peter R.]

A Lieberman > wrote:

> Maybe something to consider for future IFR students?

Keep this in mind when you get your CFII rating.

--
Peter

[A Lieberman]

On Wed, 23 Nov 2005 16:01:06 GMT, Steven P. McNicoll wrote:

>> Even though I filed direct, off airwaves, ATC recognized my limitation
>> that
>> I could only accept a standard VOR or intersection.
>>
>
> Surely you could accept an airway? What else would you expect ATC use for a
> reroute, other than VORs, intersections and airways?

Obviously airways start and terminate from an intersection or VOR. I would
have assumed you would have understood what I meant. But then assume does
have another defintion I guess.

If I have to fly to a VOR via a certain radial, to pick up an airway, no
big deal. Point I am trying to drive home is that ATC did recognize I was
slant Alpha.

> I think it likely that ATC did assume you had GPS capability precisely
> because you filed direct. They have to assume that you have the capability
> to fly what you filed and at this time it is GPS that is most likely to give
> you that capability.

I'd think you were incorrect on this. They sent me to a VOR. Doesn't the
flight strip show what I filed?

>> Had they given me a GPS intersection rather then a VOR or VOR associated
>> intersection, I would have said unable, alerting them to the fact I am
>> slant Alpha. That was the point I was trying to bring across in my
>> original post.
>>
>
> What is a "GPS intersection"?

Since I don't have an IFR GPS (yet), maybe I worded it rather poorly, but
are there not other routes that GPS may offer then standard NAV routes?

>> I would have expected a closer VOR, not one 90 miles away to go direct to.
>> As you can see, not that big a deal, but for a person like me, learning
>> the
>> ropes of IFR, when I am by myself, I don't have CRM available. Small
>> things do make a big difference.
>>
>
> Did you examine your chosen route at all when you were planning your trip?
> Almost halfway between 2G2 and BWG lie a couple of MOAs, your filed route
> goes through them. Just a few miles south of the MOAs is York VOR. Your
> reroute was probably necessary because the MOAs were in use.

Please re-read what I wrote above. As I originally posted, the MOA's were
hot, and the re-route was due to the MOAs. I would have expected a
clearance to a VOR closer to where I was and then if needed run the airways
until I am cleared the VORs.

Don't get me wrong, the clearance I received was much simpler then it could
have been, which I am gratefully thankful for, being a single pilot in IMC.

I just would have expected a clearance to a fix within a range that at
least I could have picked up on the nrst function of my GPS, not some 90
miles away.

Allen

[A Lieberman]

On Wed, 23 Nov 2005 10:59:28 -0600, A Lieberman wrote:

> Please re-read what I wrote above. As I originally posted, the MOA's were
> hot, and the re-route was due to the MOAs. I would have expected a
> clearance to a VOR closer to where I was and then if needed run the airways
> until I am cleared the VORs.

Correction. Last sentence should read:

until I am cleared the MOA.

[Steven P. McNicoll]

"A Lieberman" > wrote in message
...
>
> Obviously airways start and terminate from an intersection or VOR. I
> would have assumed you would have understood what I meant. But then
> assume does have another defintion I guess.
>

I've learned it's best not to assume anything here.


>
> If I have to fly to a VOR via a certain radial, to pick up an airway, no
> big deal. Point I am trying to drive home is that ATC did recognize I was
> slant Alpha.
>

Of course they did, it's right on the strip. But they also recognized you
had RNAV capability based of your filed route.


>
> I'd think you were incorrect on this.
>

Why?


>
> They sent me to a VOR.
>

They sent you direct to a VOR that was out of range. Doesn't that suggest
to you that they assumed you had RNAV capability? Were you originally
cleared as filed or via radar vectors? How could they clear you as filed
without assuming you had RNAV capability?

Is there another fix that would have provided sufficient avoidance of the
MOAs with less deviation than YRK VORTAC?


>
> Doesn't the flight strip show what I filed?
>

Yes, it wouldn't be very useful if it didn't.


>
> Since I don't have an IFR GPS (yet), maybe I worded it rather poorly, but
> are there not other routes that GPS may offer then standard NAV routes?
>

An intersection is a point defined by any combination of courses, radials,
or bearings of two or more navigational aids. I believe you're thinking of
waypoints.


>
> Please re-read what I wrote above. As I originally posted, the MOA's were
> hot, and the re-route was due to the MOAs. I would have expected a
> clearance to a VOR closer to where I was and then if needed run the
> airways until I am cleared the VORs.
>

A re-read confirms you didn't mention the MOAs. If you knew the MOAs were
hot why did you file a route through them?


>
> I just would have expected a clearance to a fix within a range that at
> least I could have picked up on the nrst function of my GPS, not some 90
> miles away.
>

Well, there's no reason to expect that.

[Ron Lee]

"Steven P. McNicoll" > wrote:

Steven, you could be outdoors and and ask the assembled crowd what
color the sky is. They all reply "blue" and you would still ask them
to prove it.

Ron Lee

[John R. Copeland]

"Ron Lee" > wrote in message ...
> "Steven P. McNicoll" > wrote:
>
> Steven, you could be outdoors and and ask the assembled crowd what
> color the sky is. They all reply "blue" and you would still ask them
> to prove it.
>
> Ron Lee

Heh, heh. Where Steven lives, there's a *lot* of gray sky.
He'd have a right to be skeptical. :-)

[A Lieberman]

On Wed, 23 Nov 2005 19:01:21 GMT, Steven P. McNicoll wrote:

>> If I have to fly to a VOR via a certain radial, to pick up an airway, no
>> big deal. Point I am trying to drive home is that ATC did recognize I was
>> slant Alpha.
>>
>
> Of course they did, it's right on the strip. But they also recognized you
> had RNAV capability based of your filed route.

I'd have to respectfully disagree, as RNAV capability should be filed as
follows:

/Y LORAN, VOR/DME, or INS with no transponder
/C LORAN, VOR/DME, or INS with transponder (No Mode C)
/I LORAN, VOR/DME, or INS with transponder (Mode C)

Since I filed /A direct, that does not give any indication I have RNAV
capability.

Unless of course you wish to use that word assume, which you said yourself,
you don't do in newsgroups.

Allen

[Ron Garret]

In article et>,
"Steven P. McNicoll" > wrote:

> "Newps" > wrote in message
> ...
> >
> > Have you asked this question to FSDO?
> >
>
> I did. About six years ago I sent the following message to eleven of the
> fourteen FSDOs in the Great Lakes Region:

I must say you did your homework thoroughly (more thoroughly than anyone
at the FSDOs you corresponded with).

Nonetheless, I predict that if you ever got yourself into trouble using
a VFR GPS to navigate off-airways they'd nail you on a violation of
91.205(d)(2) (not to mention that old standby, 91.13).

"For IFR flight the following ... are required: ... navigational
equipment appropriate to the ground facilities being used."

This regulation was clearly written in the days before GPS, and it
hinges entirely on the meaning of the word "appropriate." But I think
it would be a mighty tough row to hoe in front of an administrative law
judge that a GPS that is explicitly not approved for IFR navigation is
nevertheless "appropriate" for IFR navigation, or that the reg is not
applicable because the GPS satellites aren't on the ground.

rg

[Ron Garret]

In article >,
Ron Garret > wrote:

> In article et>,
> "Steven P. McNicoll" > wrote:
>
> > "Newps" > wrote in message
> > ...
> > >
> > > Have you asked this question to FSDO?
> > >
> >
> > I did. About six years ago I sent the following message to eleven of the
> > fourteen FSDOs in the Great Lakes Region:
>
> I must say you did your homework thoroughly (more thoroughly than anyone
> at the FSDOs you corresponded with).
>
> Nonetheless, I predict that if you ever got yourself into trouble using
> a VFR GPS to navigate off-airways they'd nail you on a violation of
> 91.205(d)(2) (not to mention that old standby, 91.13).
>
> "For IFR flight the following ... are required: ... navigational
> equipment appropriate to the ground facilities being used."
>
> This regulation was clearly written in the days before GPS, and it
> hinges entirely on the meaning of the word "appropriate." But I think
> it would be a mighty tough row to hoe in front of an administrative law
> judge that a GPS that is explicitly not approved for IFR navigation is
> nevertheless "appropriate" for IFR navigation, or that the reg is not
> applicable because the GPS satellites aren't on the ground.

Followup: there's also AIM 1-1-19 (d)(1)(a): "... VFR and handheld GPS
systems are not authorized for IFR navigation ... [under IFR] they may
be considered only an aid to situational awareness."

The AIM is not regulatory, but could reasonably be brought to bear when
determining the meaning of the word "appropriate" in FAR 91.205(d)(2).

I note in passing that the AIM 1-1-19(b)(3) has an extensive discussion
of the risks of relying on a VFR GPS in IMC.

rg

[Bob Noel]

In article >,
Ron Garret > wrote:

> Followup: there's also AIM 1-1-19 (d)(1)(a): "... VFR and handheld GPS
> systems are not authorized for IFR navigation ... [under IFR] they may
> be considered only an aid to situational awareness."
>
> The AIM is not regulatory, but could reasonably be brought to bear when
> determining the meaning of the word "appropriate" in FAR 91.205(d)(2).
>
> I note in passing that the AIM 1-1-19(b)(3) has an extensive discussion
> of the risks of relying on a VFR GPS in IMC.

and note that the AIM has been updated a few times with the intent of
clarifying the use of handheld GPS for IFR operations. IOW - the FAA has
had many chances to "correct" the AIM.

--
Bob Noel
New NHL? what a joke

[Steven P. McNicoll]

"A Lieberman" > wrote in message
. ..
>
> I'd have to respectfully disagree, as RNAV capability should be filed as
> follows:
>
> /Y LORAN, VOR/DME, or INS with no transponder
> /C LORAN, VOR/DME, or INS with transponder (No Mode C)
> /I LORAN, VOR/DME, or INS with transponder (Mode C)
>

As well as /E, /F, /G, /R, /J, /K, /L, and /Q.


>
> Since I filed /A direct, that does not give any indication I have RNAV
> capability.
>

Yes it does. Any time you file a direct route between airports hundreds of
miles apart you're indicating you have RNAV capability. Do you really think
ATC will conclude you cannot navigate the route you filed because you filed
/A and then clear you as filed?


>
> Unless of course you wish to use that word assume, which you said
> yourself, you don't do in newsgroups.
>

Can you see now why I don't assume anything in these groups?

[Steven P. McNicoll]

"A Lieberman" > wrote in message
. ..
>
> I'd have to respectfully disagree, as RNAV capability should be filed as
> follows:
>
> /Y LORAN, VOR/DME, or INS with no transponder
> /C LORAN, VOR/DME, or INS with transponder (No Mode C)
> /I LORAN, VOR/DME, or INS with transponder (Mode C)
>

As well as /E, /F, /G, /R, /J, /K, /L, and /Q.


>
> Since I filed /A direct, that does not give any indication I have RNAV
> capability.
>

Yes it does. Any time you file a direct route between airports hundreds of
miles apart you're indicating you have RNAV capability. Do you really think
ATC will conclude you cannot navigate the route you filed because you filed
/A and then clear you as filed?


>
> Unless of course you wish to use that word assume, which you said
> yourself, you don't do in newsgroups.
>

Can you see now why I don't assume anything in these groups?

[A Lieberman]

On Thu, 24 Nov 2005 06:55:52 GMT, Steven P. McNicoll wrote:

>> Since I filed /A direct, that does not give any indication I have RNAV
>> capability.
>>
>
> Yes it does. Any time you file a direct route between airports hundreds of
> miles apart you're indicating you have RNAV capability. Do you really think
> ATC will conclude you cannot navigate the route you filed because you filed
> /A and then clear you as filed?

I reiterate, I filed /a

Filing slant alpha does not infer I have RNAV capability. I don't care if
it's 30 miles or 300 miles.

I could fly by wet compass and stop watch in theory (dead reckoning).

You said you don't want to use the word assume..... What you say above
infers that ATC will assume.....

[Steven P. McNicoll]

"A Lieberman" > wrote in message
...
>
> I reiterate, I filed /a
>

Yes, I know. Try to understand, filing /A does NOT mean that you have no
RNAV capability. It's quite common for pilots to file /A and navigate with
handheld GPS.


>
> Filing slant alpha does not infer I have RNAV capability. I don't care if
> it's 30 miles or 300 miles.
>

No, filing /A does not imply that you have RNAV capability, but filing
direct from one airport to another one 337 miles away does.


>
> I could fly by wet compass and stop watch in theory (dead reckoning).
>
> You said you don't want to use the word assume..... What you say above
> infers that ATC will assume.....
>

I didn't say I don't want to use the word assume, I said I've learned it's
best not to assume anything in these forums. ATC inferred you had some RNAV
capability because you implied it when you filed direct from 2G2 to BWG. If
they hadn't assumed you had RNAV capability you wouldn't have been cleared
as filed, and you wouldn't have been cleared direct to a fix some ninety
miles away.

[Doug]

Fight! Fight!

Hey Steve, I win!

I have proof at :
http://googlefight.com/index.php?lang=en_GB&word1=Steve+McNicholl&word2=Doug

Nice try though....

[Robert M. Gary]

What if I'm using a ham sandwich?

[Robert M. Gary]

Steve has some classics. I'll never forget the time he argued what I
though of ATC in socal. Apparently, he was arguing that I really did
like it! :) He also argued that I didn't actually do my 3 night
currency landings during the post-9/11 IFR only time. After I gave him
the name and ATC phone number of the controller who issued me the
multiple IFR releases (since tower asked me to call approach directly
on the land line with my strange request) with immediate clearances for
the visual approach, he refused to call it but still said I made it up.
Classic

-Robert

[Steven P. McNicoll]

"Robert M. Gary" > wrote in message
oups.com...
>
> Steve has some classics. I'll never forget the time he argued what I
> though of ATC in socal. Apparently, he was arguing that I really did
> like it! :) He also argued that I didn't actually do my 3 night
> currency landings during the post-9/11 IFR only time. After I gave him
> the name and ATC phone number of the controller who issued me the
> multiple IFR releases (since tower asked me to call approach directly
> on the land line with my strange request) with immediate clearances for
> the visual approach, he refused to call it but still said I made it up.
> Classic
>

Sounds like you're remembering some odd dream.

[Newps]

Robert M. Gary wrote:
> What if I'm using a ham sandwich?

Can you get those with moving maps now?

[Doug]

Just to interject a comment here. Use of a handheld to supplement other
instruments, or even to supplement radar vectors, under IFR flight
rules, is what I would call a gray area of FAA rules. On the one hand
it's not really expressly PROHIBITED. But it's not expressly permitted
either. The OFFICIAL word, because of liability and the FAA's history
of wanting things to be certified, is you can't do it. But because
handhelds do function as useful navigation devices quite well, the
UNOFFICIAL rule is, if it works, you can do it.

It's not much different than using a handheld VOR (which exist and do
work) for VOR navigation. But since GPS works so much better, and
almost all aircraft flown IFR have VORs , the subject doesn't get
questioned.

What ATC wants is for you to be able to fly your clearance. Its really
up to you how you do it.

Things would start falling apart though, if there were an accident, and
the accident could be atrributed to incorrect navigation on the part of
the pilot using the handheld device. I am sure the FAA would see a
violation on that. I've seen a few FAA violations after accidents, and
they can violate the pilot, oh yes they can, and do. And they just do
it and you don't have much recourse. They will find some reason.

But so long as you keep your mouth shut, fly your clearance, and don't
cause problems, there is no citation.

The FAA used to publicize that pilots were PROHIBITIED from using
handhelds for navigation. But that has stopped. There seems to a quiet
acceptance that pilots can use them, so long as it doesn't cause
problems. Probably legal for VFR flight, where your primary navigation
is by eyesight anyway. Probably not strictly legal for IFR flight, but
can be used safely if you have the required navigation systems in the
airplane. Probably not a good idea for IFR flight if you don't have the
required, certified navigation system in the airplane.

IFR GPS's are getting inexpensive enough so that it's becoming a moot
point anyway. Why not just get a used King KLN89 and get it certified
and you will have all you legally need to file /G, no questions asked.
Then use your handheld as a backup to that unit, if it fails. And as a
backup to that unit if there is any ambiguity on the integrety of the
signal. If both units don't agree, there is a problem. If one unit
fails and the other doesn't that tells you its the unit and not the
satellites etc. For full safety you need two units anyway. The reason
why most IFR aircraft have two VOR's, not one. Safe IFR flight is all
about having redundancy. A handheld gives good redundancy to a built in
unit.

Stay safe!

[Ron Garret]

In article om>,
"Doug" > wrote:

> Just to interject a comment here. Use of a handheld to supplement other
> instruments, or even to supplement radar vectors, under IFR flight
> rules, is what I would call a gray area of FAA rules. On the one hand
> it's not really expressly PROHIBITED. But it's not expressly permitted
> either. The OFFICIAL word, because of liability and the FAA's history
> of wanting things to be certified, is you can't do it.

Not so. The AIM specifically endorses the use of handheld GPS as an aid
to situational awareness.

rg

[Jose]

> [re:] Use of a handheld to supplement other instruments. [...]
> The OFFICIAL word, because of liability and the FAA's history
> of wanting things to be certified, is you can't do it.

Where is this official word (specifically prohibiting use as a supplement)?

Jose
--
You can choose whom to befriend, but you cannot choose whom to love.
for Email, make the obvious change in the address.

[Newps]

Doug wrote:

> Just to interject a comment here. Use of a handheld to supplement other
> instruments, or even to supplement radar vectors, under IFR flight
> rules, is what I would call a gray area of FAA rules.

It's not gray. You are on a vector.


On the one hand
> it's not really expressly PROHIBITED. But it's not expressly permitted
> either. The OFFICIAL word, because of liability and the FAA's history
> of wanting things to be certified, is you can't do it. But because
> handhelds do function as useful navigation devices quite well, the
> UNOFFICIAL rule is, if it works, you can do it.

Not correct. The FAA isn't going to list everything you can do to help
yourself stay aware in the cockpit, that would be ridiculous. If
hanging a pencil by a string from the overhead vent helps you fly your
assigned heading then do it. But you still gotta fly the assigned heading.


>
> It's not much different than using a handheld VOR (which exist and do
> work) for VOR navigation. But since GPS works so much better, and
> almost all aircraft flown IFR have VORs , the subject doesn't get
> questioned.

As long as the GPS can keep you on the centerline. Many airways have
intersections with slight turns, some with large turns. This makes it
harder to use a GPS for airways if the GPS doesn't have the airways in
the database.


>
> What ATC wants is for you to be able to fly your clearance. Its really
> up to you how you do it.

Right, ATC doesn't get into enforcement. You can very easily, and much
more accurately, fly an NDB approach with a handheld GPS. But it ain't
legal. Same with direct using a handheld. Your beef will be with FSDO.


>
> Things would start falling apart though, if there were an accident, and
> the accident could be atrributed to incorrect navigation on the part of
> the pilot using the handheld device. I am sure the FAA would see a
> violation on that. I've seen a few FAA violations after accidents, and
> they can violate the pilot, oh yes they can, and do. And they just do
> it and you don't have much recourse. They will find some reason.

They don't have to go fishing for a reason. These FSDO guys get out in
the field and visit us in the tower also. They see things and then they
investigate, no accident necessary.


>
> But so long as you keep your mouth shut, fly your clearance, and don't
> cause problems, there is no citation.

Maybe. Maybe not.

[Robert M. Gary]

Steven said:
> Sounds like you're remembering some odd dream.

Yes, in Steven's world, people dream about him. :)

-Robert

[Ron Lee]

Ron Garret > wrote:
>> Just to interject a comment here. Use of a handheld to supplement other
>> instruments, or even to supplement radar vectors, under IFR flight
>> rules, is what I would call a gray area of FAA rules. On the one hand
>> it's not really expressly PROHIBITED. But it's not expressly permitted
>> either. The OFFICIAL word, because of liability and the FAA's history
>> of wanting things to be certified, is you can't do it.
>
>Not so. The AIM specifically endorses the use of handheld GPS as an aid
>to situational awareness.
>
>rg

Which is different than a primary means of navigation.

Ron Lee

[A Lieberman]

On Mon, 28 Nov 2005 08:52:22 -0700, Newps wrote:

> Robert M. Gary wrote:
>> What if I'm using a ham sandwich?
>
> Can you get those with moving maps now?

Only with cheese on top :-)

[Matt Barrow]

"A Lieberman" > wrote in message
.. .
> On Mon, 28 Nov 2005 08:52:22 -0700, Newps wrote:
>
>> Robert M. Gary wrote:
>>> What if I'm using a ham sandwich?
>>
>> Can you get those with moving maps now?
>
> Only with cheese on top :-)

Swiss map.

[Wizard of Draws]

On 11/28/05 1:10 PM, in article
om, "Doug"
> wrote:

>
> IFR GPS's are getting inexpensive enough so that it's becoming a moot
> point anyway. Why not just get a used King KLN89 and get it certified
> and you will have all you legally need to file /G, no questions asked.
> Then use your handheld as a backup to that unit, if it fails. And as a
> backup to that unit if there is any ambiguity on the integrety of the
> signal. If both units don't agree, there is a problem. If one unit
> fails and the other doesn't that tells you its the unit and not the
> satellites etc. For full safety you need two units anyway. The reason
> why most IFR aircraft have two VOR's, not one. Safe IFR flight is all
> about having redundancy. A handheld gives good redundancy to a built in
> unit.
>
> Stay safe!
>

Renters don't have the option of installing IFR certified GPS units in the
aircraft they fly. As the next best option, I bought an Airmap 2000C.
--
Jeff 'The Wizard of Draws' Bucchino

Cartoons with a Touch of Magic�
http://www.wizardofdraws.com

More Cartoons with a Touch of Magic�
http://www.cartoonclipart.com

[Roy Smith]

Wizard of Draws > wrote:

> Renters don't have the option of installing IFR certified GPS units in the
> aircraft they fly. As the next best option, I bought an Airmap 2000C.

Renters do have the option of not renting planes that aren't equipped the
way they want. We're rapidly getting to the point where anything that
doesn't have at least an en-route IFR certified GPS is unmarketable as a
rental. My club is already on its third generation of GPS boxes.

[Ron Garret]

In article >,
(Ron Lee) wrote:

> Ron Garret > wrote:
> >> Just to interject a comment here. Use of a handheld to supplement other
> >> instruments, or even to supplement radar vectors, under IFR flight
> >> rules, is what I would call a gray area of FAA rules. On the one hand
> >> it's not really expressly PROHIBITED. But it's not expressly permitted
> >> either. The OFFICIAL word, because of liability and the FAA's history
> >> of wanting things to be certified, is you can't do it.
> >
> >Not so. The AIM specifically endorses the use of handheld GPS as an aid
> >to situational awareness.
> >
> >rg
>
> Which is different than a primary means of navigation.

That's true, but what does that have to do with the matter under
discussion?

rg

[Jose]

>>Which is different than a primary means of navigation.
>
>
> That's true, but what does that have to do with the matter under
> discussion?

The constant use of "use" to mean "rely on", and the resulting commotion
while posters who successfully tricked people into their game snicker.

Jose
--
You can choose whom to befriend, but you cannot choose whom to love.
for Email, make the obvious change in the address.

[Steven P. McNicoll]

"Newps" > wrote in message
. ..
>
> It's not gray. You are on a vector.
>

You are on a vector when and only when you're instructed to fly a specific
heading or when instructed to turn a specific number of degrees in a
specific direction.


>
> Right, ATC doesn't get into enforcement. You can very easily, and much
> more accurately, fly an NDB approach with a handheld GPS. But it ain't
> legal. Same with direct using a handheld. Your beef will be with FSDO.
>

There's nothing illegal in the use of a handheld GPS for IFR enroute flight
in US controlled airspace.

[Ron Garret]

In article . net>,
"Steven P. McNicoll" > wrote:

> > Right, ATC doesn't get into enforcement. You can very easily, and much
> > more accurately, fly an NDB approach with a handheld GPS. But it ain't
> > legal. Same with direct using a handheld. Your beef will be with FSDO.
> >
>
> There's nothing illegal in the use of a handheld GPS for IFR enroute flight
> in US controlled airspace.

There is if you use it for primary navigation, which you would be if you
were flying direct to an intersection rather than a VOR, or direct to a
VOR that you can't receive at your current location.

rg

[Steven P. McNicoll]

"Ron Garret" > wrote in message
...
>
> There is if you use it for primary navigation, which you would be if you
> were flying direct to an intersection rather than a VOR, or direct to a
> VOR that you can't receive at your current location.
>

What law would that violate?

[Ron Garret]

In article . net>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > There is if you use it for primary navigation, which you would be if you
> > were flying direct to an intersection rather than a VOR, or direct to a
> > VOR that you can't receive at your current location.
> >
>
> What law would that violate?

FAR 91.205(d)(2)

I pointed this out earlier. See
http://groups.google.com/group/rec.aviation.ifr/msg/614a4e29a423522f

rg