FAA Policy Change Voids Many IFR GPS Units

[Brantel]

Originally Posted by DGlaeser

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?

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.

[dan]

Originally Posted by az_gila

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

http://www.faa.gov/about/office_org/...compliance.xls

Thanks for that link, Gil. That's exactly what I was looking for (why didn't AOPA didn't present that to us?).

[hevansrv7a]

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.

[az_gila]

Originally Posted by hevansrv7a

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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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

[7pilot]

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.

[dan]

http://www.avweb.com/eletter/archive...ll.html#195316

[BuckWynd]

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."

[BuckWynd]

Dan beat me to it while I typed.

Anyway, looks like a positive turn of events...

[az_gila]

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

[dan]

Gee, didn't I say that a few days ago?

Glad more "authoritative" folks are now saying it.