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FAA Policy Change Voids Many IFR GPS Units

BuckWynd

BuckWynd

Well Known Member
This article forwarded from AvWeb, just in case some of you missed it:

"Many previously IFR-certified GPS receivers might now be unapproved for flying many instrument procedures due to recent FAA policy changes, according to AOPA.

On Thursday, the association said the FAA's Advisory Circular 90-100A, issued in March, indicates that only three GPS models -- the Garmin 400, 500 and G1000 series -- are now legal. Other models made by Garmin, including the new GNS 480 WAAS receiver, as well as receivers manufactured by Chelton, Honeywell, Northstar, and Trimble are listed as "non-compliant," AOPA said. The action means up to 26,000 GPS users no longer comply with a 1996 FAA policy that allows GPS to be used in lieu of ADF or DME.

"This doesn't make any sense. In most cases, this is not a safety of flight issue," said Randy Kenagy, AOPA senior director of strategic planning. "Pilots affected will lose access to approaches and published routes unnecessarily." AOPA has brought the matter to the FAA's attention, telling the FAA that all IFR-certified systems should still be approved for use in lieu of ADF and DME and for flying T routes and certain departure procedures where pilots manually enter the waypoints."

(Article by Chad Trautvetter, AvWeb Editor In Chief)
 
Totally without a clue decision making

It is absolutely unbelievable (I saw the announcement on AvWeb) that the FAA would do such a thing. I have an SL-60 that is very accurate and reliable and has to be used at many airports these days because I don't have an ADF or DME and didn't need them when I built the plane. Even if they want to make a change existing systems should be grandfathered and there should be a phase in to allow the pipeline to clear out. The DOT/FAA have a responsibility to provide a reliable and stable air traffic system for the aviators and they are not living up to that responsibility.

Many years ago when I was in the military I was a member of an organization called AACS which provided the all of the USAF navaids, control centers (Area D in Korea, etc.), approach control (GCA, RAPCON, etc.), control towers, base weather, etc. I worked, ate and slept with air traffic control and electronic maintenance people and we were a proud bunch. I still sense that pride and responsibility when I communicate with controllers but I think management priorities and perhaps management disability are causing problems that will only get worse in the foreseeable future. FSS is already just a shell of its former self.

Bob Axsom
 
Man this is bad....

Hopefully the efforts from the AOPA will get this fixed. Who comes up with this stuff? :confused: :confused:
 
Hmmmm!

Do you get the feeling that someone in the FAA is trying to squeeze us little guys out? Considering the debate about FAA funding, fuel taxes, user fees, etc. and then this, it is a little puzzling.

I have just inherited a 1969 C-172 with two NavComs, an ADF and a DME, Quite spiffy in its time. When we had it appraised for estate settlement purposes, I was very surprised to find out the avionics were basically a "no-adder" item. If it had any kind of panel mount GPS, it would have increased the value by $5,000. I wonder if that would be true in view of this recent FAA announcement.

And on Monday of this week, I was seriously thinking about shopping for a used Garmin 430. On the other hand, maybe they'll be an even better buy now!
Don
 
FAA employees should be pilots

I think it should be a mandatory requirement for all rules makers at FAA (especially the head FAA talking head) be pilots. If any employee is appointed to a rule making committee they should have first hand pilot experience dealing with whatever that rule is affecting. Perhaps that would weed out some of those people who are just on the dole for a paycheck. Maybe we could then have an environment in the FAA where realistic meaningful decisions can be made.

I know, I know, a pipe dream! But, hey, a fella can dream can't he? :rolleyes:
 
AOPA is sensationalizing as usual. Read AC90-100a and tell me if it really does apply to YOU.

b. Applicability of AC 90-100A. AC 90-100A applies to operation on U.S. Area Navigation (RNAV) routes (Q-routes and T-routes), Departure Procedures (Obstacle Departure Procedures and Standard Instrument Departures), and Standard Terminal Arrivals (STARs). It does not apply to over water RNAV routes (ref 14 CFR 91.511, including the Q-routes in the Gulf of Mexico and the Atlantic routes) or Alaska VOR/DME RNAV routes ("JxxxR"). It does not apply to off-route RNAV operations, Alaska GPS routes or Caribbean routes, or helicopter operations involving offshore or specific heliport procedures.
Click to expand...

If I'm going to take this AC seriously (and not just assume that AOPA is sensationalizing to rationalize its own existence), then somebody needs to tell me EXACTLY:

a) What I no longer can do with my TSOC129a Class A1 GX60.
b) If this even really does affect my IFR operations.
c) What exactly (i.e. according to the performance criteria laid out in AC90-100a) the non-compliance is.

Until then, it's business as usual for me.
 
Non-Compliance

dan said:
AOPA is sensationalizing as usual. Read AC90-100a and tell me if it really does apply to YOU.



If I'm going to take this AC seriously (and not just assume that AOPA is sensationalizing to rationalize its own existence), then somebody needs to tell me EXACTLY:

a) What I no longer can do with my TSOC129a Class A1 GX60.
b) If this even really does affect my IFR operations.
c) What exactly (i.e. according to the performance criteria laid out in AC90-100a) the non-compliance is.

Until then, it's business as usual for me.
Click to expand...

Dan... the non-compliance is detailed here in a separate Excel document on the FAA web site...

http://www.faa.gov/about/office_org.../policy_guidance/media/AC90-100compliance.xls

Seems to be a question with the selection of approaches by name, and a level of approval of the database...

"Apollo GX50
Apollo GX55
Apollo GX60
Apollo GX65"

ALL

ALL

NO, TSO-C129a but not compliant due to equipment limitation that prevents selection of named departure and/or arrival procedures. No plans to obtain Type 2 LOA for navigation database.

N/A. ?N/A? in the ?DME/DME(/IRU) Eligibility? column means that the listed model does not include any DME/DME navigation function.

gil in Tucson.... glad to be VFR at this time.... :)
 
dan said:
AOPA is sensationalizing as usual. Read AC90-100a and tell me if it really does apply to YOU.

If I'm going to take this AC seriously (and not just assume that AOPA is sensationalizing to rationalize its own existence), then somebody needs to tell me EXACTLY:
a) What I no longer can do with my TSOC129a Class A1 GX60.
b) If this even really does affect my IFR operations.
c) What exactly (i.e. according to the performance criteria laid out in AC90-100a) the non-compliance is.
Until then, it's business as usual for me.
Click to expand...
The way I read it, this affects the use of GPS to replace DME fixes and NDBs. So, for instance, what you'd no longer be able to do is use a GPS for an NDB approach, or use GPS to replace a DME fix on any approach. If there is a defined GPS approach you can use instead, it's no big deal. If the DME or NDB fixes are all that's there, you're out of luck. If the NDB is the only FAF specified for an ILS, that may be another one.
I don't think the AOPA is sensationalizing, I think they are calling the FAA to task for another unjustified change in policy. If they get away with this one, what's next?
 
DGlaeser said:
The way I read it, this affects the use of GPS to replace DME fixes and NDBs. So, for instance, what you'd no longer be able to do is use a GPS for an NDB approach, or use GPS to replace a DME fix on any approach. If there is a defined GPS approach you can use instead, it's no big deal. If the DME or NDB fixes are all that's there, you're out of luck. If the NDB is the only FAF specified for an ILS, that may be another one.
I don't think the AOPA is sensationalizing, I think they are calling the FAA to task for another unjustified change in policy. If they get away with this one, what's next?
Click to expand...

Thats the way I see it as well. The EAA is also on the chase as of this morning per Randy Hansen, EAA Government Relations Director. No big deal for people blessed with ILS and GPS approaches all over the place but around here where the NDB, SDF & LOC approaches are king, it is a big deal.
 
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Second Thoughts

AC 90-100A

I am having second thoughts about what this really means.

"b. Applicability of AC 90-100A. AC 90-100A applies to operation on U.S. Area Navigation (RNAV) routes (Q-routes and T-routes), Departure Procedures (Obstacle Departure Procedures and Standard Instrument Departures), and Standard Terminal Arrivals (STARs). It does not apply to over water RNAV routes (ref 14 CFR 91.511, including the Q-routes in the Gulf of Mexico and the Atlantic routes) or Alaska VOR/DME RNAV routes ("JxxxR"). It does not apply to off-route RNAV operations, Alaska GPS routes or Caribbean routes, or helicopter operations involving offshore or specific heliport procedures."

The above seems to say that it applies to RNAV and Q/T routes, DP's and STAR's. I don't see anything about ILS approaches for example. So, I don't see how it affects use of GPS to navigate to/from DME or NDB.

"(4) Whenever possible, RNAV routes should be extracted from the database in their entirety, rather than loading RNAV route waypoints from the database into the flight plan individually. Selecting and inserting individual, named fixes from the database is permitted, provided all fixes along the published route to be flown are inserted.
Page 12
Par 10a(5)
03/01/07 AC 90-100A
NOTE: This does not preclude the use of panel-mount GPS/GNSS avionics to meet the requirements of this AC to fly RNAV routes.
(5) Manual entry of waypoints using latitude/longitude or place/bearing is not permitted. Additionally, pilots must not change any RNAV DP or STAR database waypoint type from a fly-by to a fly-over or vice versa."

The above seems to say that if your instrument/DB does not have the named DP/STAR or whatever that you can enter the fixes as long as you do it completely. You just cannot enter the position of the fix if the DB doesn't already know it. The "to be flown" part seems to say that you don't have to enter the entire DP/STAR, just the part of it you are going to fly. What's the big deal, I wonder?

OK, so now I am puzzled. Do I just not understand the situation (distinctly possible) or did AOPA over react? Except for that table of OK vs. Not OK, I don't see anything that would keep us from using IFR GPS's instead of DME's and/or ADF's.
 
Database quality

hevansrv7a said:
AC 90-100A

,,,,,

OK, so now I am puzzled. Do I just not understand the situation (distinctly possible) or did AOPA over react? Except for that table of OK vs. Not OK, I don't see anything that would keep us from using IFR GPS's instead of DME's and/or ADF's.
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Click to expand...

I think this bit may be part of the problem...

14. Database Integrity. The navigation database should be obtained from a database supplier holding an FAA Letter of Acceptance (LOA) in accordance with AC 20-153. This LOA provides recognition of a data supplier?s compliance with the data quality, integrity and quality management practices of RTCA DO-200A, Standards for Processing Aeronautical Data. The
operator?s supplier (e.g., FMS manufacturer) must have a Type 2 LOA. Discrepancies that invalidate a procedure must be reported to the database supplier and affected procedures must be prohibited by an operator?s notice to its flight crew. Aircraft operators should consider the need
to conduct ongoing checks of the operational navigation databases in order to meet existing quality system requirements.
NOTE: AC 20-153 contains procedures for database LOAs.

It seems from the spreadsheet I linked earlier that Garmin will not meet this requirement for the GX and 150/300 series equipment...

gil in Tucson
 
This is bad. I just bought a 480

:eek: I just bought a new GNS 480 - it is still in the box. This has to get fixed. I don't know if they would give me full credit to change at this point or not. I don't want to live with this kind of restriction. I thought the Victor airways and a couple of the other features would be nice over the 430 I had in my last plane. Now I wonder if I have totally screwed up.
 
Latest Update to GPS issue

It appears the FAA may be reconsidering its stance on this issue. The following is quoted from the 31 May 2007 issue of AvWeb:

"Recent reports raising concerns about the FAA's approval -- or lack of approval -- of many GPS units for instrument flight have raised questions that still are being sorted out. The Aircraft Electronics Association says the confusion, arising from recently issued FAA Advisory Circular 90-100A, stems from the FAA's deletion of a paragraph in an update of the Aeronautical Information Manual (AIM). The AEA said in a statement on Wednesday that FAA officials had told them 'this oversight should be corrected in the next 10 days.'

Alison Duquette, a spokeswoman for the FAA, told AVweb on Wednesday, 'The FAA is working with the manufacturing community and AOPA to resolve the issues. The bottom line is that the previous allowances still apply, so the operators can still fly using whatever GPS system they have.' According to the AEA, the basic criteria for VFR and IFR use of GPS as a supplemental means of navigation as described in the AIM is unchanged. 'The Association is disappointed with the Agency's communications on this issue,' the AEA said, but added that it was pleased with the FAA's response to help to clarify the situation, and commended AOPA's Randy Kenegy for bringing the issue to light."
 
Over-reaction?

This came from the Grumman Association (AYA) Safety Director

[Levy] Just spoke with the folks at AFS-410 -- the people who write the rules on GPS use. According to them, the ONLY thing affected is RNAV SID's and RNAV STAR's -- and there ain't many of them. Substitution of GPS for ADF/DME is NOT affected, and use of approach-certified units for approaches is NOT affected. He said AOPA is blowing this all out of proportion, and reading into the AC stuff that isn't there. Also, there is no change to the GPS usage (Table 1-1-5) or substitution (Table 1-1-6) tables in the AIM.

IOW, relax -- keep doing business like you always have and you'll be fine.

Ron

Hope this makes sense to you IFR guys....

gil in Tucson
 
Gee, didn't I say that a few days ago? :rolleyes:

Glad more "authoritative" folks are now saying it.
 
Me too

dan said:
Gee, didn't I say that a few days ago? :rolleyes:

Glad more "authoritative" folks are now saying it.
Click to expand...
That was how I read it, too. My lengthy post is above.

Imagine how the government will handle "immigration" and "health care" and "the environment" if it cannot even accurately and effectively communicate one simple change in existing rules which only affect experts (us).
 
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