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#151
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IFR use of handheld GPS
Steven P. McNicoll wrote:
"Sam Spade" wrote in message news:Ygp7g.175614$bm6.138484@fed1read04... As they probably find you to be a bit closed-mind. You'll never find anyone more open-minded than me. Thanks for helping me on that one, too! |
#152
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IFR use of handheld GPS
Ted wrote:
"Sam Spade" wrote in message news:5Gm7g.175502$bm6.155268@fed1read04... Steven P. McNicoll wrote: "Sam Spade" wrote in message news:z%g7g.175498$bm6.169019@fed1read04... Where is your reference that GPS is primary for sole means en route navigation? I don't need one. The burden of proof is on those that claim it's use is prohibited. It's up to them to cite the FAR that prohibits such use. That is a giant load of crap. It seems like a basic tenet of the law to me. Where did you learn how to follow rules that don't exist? Who me? I agree with you. |
#153
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IFR use of handheld GPS
Steven P. McNicoll wrote:
"Sam Spade" wrote in message news:Wip7g.175615$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****. |
#154
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IFR use of handheld GPS
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. |
#155
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IFR use of handheld GPS
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. |
#156
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IFR use of handheld GPS
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. |
#157
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IFR use of handheld GPS
"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". |
#158
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IFR use of handheld GPS
"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. |
#159
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IFR use of handheld GPS
"Sam Spade" wrote in message news:gmJ7g.175942$bm6.83898@fed1read04... Travis Marlatte wrote: Steven is correct. Keep in mind that the AIM is not regulatory. Plus, the fact that Alaska has special rules does not mean anything for the other 49 states. But Part 95 is. ....irrelevant to the subject under discussion. |
#160
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IFR use of handheld GPS
Steven P. McNicoll wrote:
"Sam Spade" wrote in message newskp7g.175617$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. |
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