Minimal Compliance with 91.205 for IFR

[Bcone1381]

I now understand better the regulatory requirements of VOR navigation and GPS navigation. Now lets move the discussion towards Practicality.

Because I don't fly into small airports, I don't understand the IFR environment there, but will be operating into them in the future. I get the feeling as though it may not be practical these days to fly IFR with no GPS. Is it common for runways at smaller non controlled airports to be served only by an RNAV GPS IAP? Are the days of practical VOR/ILS approaches history? I do recall the vast number of airports with no VOR approach, and only an NDB IAP.

BTW, the university where I was trained in the 1980's we flew a LOC/BC (Loc/BC = Localizer Back Course approach...i don't see them much any more) in a C-152 with a single Nav radio. The IAP had a step down fix defined by a crossing VOR radial. We would switch back and forth a few times checking the radial as we proceeded inbound on the Back Course. If the instructor was nice we could ask ATC to call out passing the step down fix. Back then it was the prudent legal thing to do.

BTW, if I subtract the cost of the equipment that the Garmin GTN635 could replace, the real cost comes in at around $7000. $8000 for the GTN650 which ads VOR/ILS.

[snopercod]

Originally Posted by YellowJacket RV9

Another case of regulations keeping us less safe.

Amen to that! I would feel quite comfortable flying a GPS approach using my $1,500 iPad/Foreflight/Stratus2 setup, but it's "illegal" on a number of levels. Clearly the FAA is holding us experimental guys back.

[maniago]

Originally Posted by Bcone1381

. Is it common for runways at smaller non controlled airports to be served only by an RNAV GPS IAP?

In short, yes.

In long, yes and thats all there will ever be for them.

I've been looking at the same equipage issues and regs as yourself for at least 3 yrs (as I continue to build) and in the end, I keep coming back to the only practical/cost effective IFR solution is a WAAS GPS, 430W or better. Thats why their prices, which should have gone down to the 1k range, remain in the 6-7k range. Still very painful.

[BillL]

Hopefully not off topic. I have recently been alerted to this need.

In the AIM there is this statement:

"To satisfy the requirement for two independent navigation systems, if the primary navigation system is GPS−based, the second system must be independent of GPS (for example, VOR or DME/DME/IRU). This allows continued navigation in case of failure of the GPS or WAAS services."

In the AIM search for "The requirements for a second system"

It is stated that this avoids the single point of failure (GPS jamming or outage) for an IFR flight.

As a result I am adding an antenna to my 650, but is there some exception to this statement? Do we experimental need to address this "requirement"?

[Auburntsts]

Originally Posted by BillL

Hopefully not off topic. I have recently been alerted to this need.

In the AIM there is this statement:

"To satisfy the requirement for two independent navigation systems, if the primary navigation system is GPS−based, the second system must be independent of GPS (for example, VOR or DME/DME/IRU). This allows continued navigation in case of failure of the GPS or WAAS services."

In the AIM search for "The requirements for a second system"

It is stated that this avoids the single point of failure (GPS jamming or outage) for an IFR flight.

As a result I am adding an antenna to my 650, but is there some exception to this statement? Do we experimental need to address this "requirement"?

That para and requirement refers to air carrier/commercial operations. What you referenced is sub-para (d) to para (5) Air carrier and commercial operators must meet the appropriate provisions of their approved operations specifications , under para (b) Database Requirements, under para 2. IFR Use of GPS, under section 1-1-17 Global Positioning System (GPS). The rest of sub-para (d) states "Recognizing that GPS interference and test events resulting in the loss of GPS services have become more common, the FAA requires operators conducting IFR operations under 14 CFR 121.349, 125.203, 129.17 and 135.65 to retain a non-GPS navigation capability consisting of either DME/DME, IRU, or VOR for en route and terminal operations, and VOR and ILS for final approach. Since this system is to be used as a reversionary capability, single equipage is sufficient."

For part 91 ops if you have a TSO-145/146 IFR WAAS GPS then you are approved for standalone IFR ops. Having said that, I'd recommend retaining VOR/LOC/GS capability in the event of a GPS outage. The latest AIM has a new section that talks to the VOR MON architecture and capabilities to support such a GPS outage.

[Icarus]

Originally Posted by Auburntsts

For part 91 ops if you have a TSO-145/146 IFR WAAS GPS then you are approved for standalone IFR ops. Having said that, I'd recommend retaining VOR/LOC/GS capability in the event of a GPS outage. The latest AIM has a new section that talks to the VOR MON architecture and capabilities to support such a GPS outage.

Great input, one thousand times over. VORs are not "going away", but sure will get thinned out (and already are). They considered many backup systems to the VOR, including LORAN (seriously, they did), but try as they may...they settled with the MON system and it's VORs. GPS is the way to go, no arguments there. But a VOR backup is still very much in fashion.

[Bcone1381]

Lets move the discussion on to the next step....what to do.

The consensus I sense is that the experimental IFR operator is provided with a number of very nice, safe, cutting edge, navigation options with capabilty of safely and reliably delivering guidance information to minimums on an LPV or LNAV instrument approach procedure. Am I right?

But, these avionics designed for the EAB market are merely "tantalizing & illegal" eye candy for primary IFR navigation, outside of a $10,000 price tag.

If paragraph #2 is accurate, we should speak up as a group.

Do we need to be requesting for a more honed product from the avionics suppliers? (Maybe its already there, but it lacks approval?) (It just dawned on me that the Suppliers are the experts to solving this. They know why its not approved, and what the hurdles are that prevent approval.)

Do we collect and organize flight data from ourselves, using the data recorders that many of you have, and present a truthful, data driven presentation with our request?

Do we need to start asking the public servants at the EAA, and FAA some tough questions? What are those questions?

Could we even get the suppliers, the EAA, and the FAA to sit down with us and discuss our problem? This ought to maybe be a group focus as we go to OSH next week.

[airguy]

Originally Posted by Bcone1381

But, these avionics designed for the EAB market are merely "tantalizing & illegal" eye candy for primary IFR navigation, outside of a $10,000 price tag.

For now, yes.

Originally Posted by Bcone1381

(It just dawned on me that the Suppliers are the experts to solving this. They know why its not approved, and what the hurdles are that prevent approval.)

Precisely - and some are working on it, but won't announce anything publicly until they have a final product ready for sale. Don't expect an acknowledgment or discussion of the pending product from them until then.

[Auburntsts]

Originally Posted by Bcone1381

Lets move the discussion on to the next step....what to do.

The consensus I sense is that the experimental IFR operator is provided with a number of very nice, safe, cutting edge, navigation options with capabilty of safely and reliably delivering guidance information to minimums on an LPV or LNAV instrument approach procedure. Am I right?

No-absolutely not. The VFR GPS's out there do not have the full approach databases to legally shoot any approach nor do they have the fault detection and annunciation required to safely do so (that's there the TSOs comes in).

I'm sorry but there is no cheap way to add an IFR GPS approach capability at this time. Nor does having a E-AB certificated aircraft give anyone a pass around the legal requirements.

[flytoboat]

What Todd said +1! There are no short cuts for IFR for E-AB. We do have some real nice EFIS systems and integrated auto pilot options though, that are much cheaper than certified.
Been following this thread since the beginning and still trying to figure out your angle. What RV are you flying???