Equipment Suffix

[Don Jones]

I know this has been covered extensively on the other board, but I would like a clarification. I have a panel mount IFR certified GPS, but it is not an IFR certified installation since it lacks an annunciator panel and external CDI. Can I file /G? I heard somewhere I could but I want to know for sure.
Inquiring minds want to know the real truth.
Don

 

[BruceAir]

From the AOPA/ASF Safety Advisor on GPS:

What specific avionics have to be installed in an
aircraft to file a /G flight plan?

The aircraft must have an IFR certified GPS and the
GPS Flight Manual Supplement must be on the aircraft.
​

Note that not all IFR GPS installations require separate indicators and annunciators. Many newer units incorporate those items in the panel unit itself.

But if your unit/installion isn't approved for IFR operation, you should have a placard saying it's for VFR only. And you should have a supplement in your approved airplane manual describing any limitations on its use.

You can find more information in the AIM and Advisory Circular AC 90-94A, Guidelines for Operators using Global Positioning System Equipment for IFE En Route and Terminal Operations and for Nonprecision Instrument Approaches in the U.S. National Airspace System

 

[Ed Guthrie]

I know this has been covered extensively on the other board, but I would like a clarification. I have a panel mount IFR certified GPS, but it is not an IFR certified installation since it lacks an annunciator panel and external CDI. Can I file /G? I heard somewhere I could but I want to know for sure.
Inquiring minds want to know the real truth.
Don

Bruce's quotes from AOPA may have been less than clear. To keep it simple: No, no /G for your aircraft if the installation is not IFR approved and capable.

 

[John J]

Bruce's quotes from AOPA may have been less than clear. To keep it simple: No, no /G for your aircraft if the installation is not IFR approved and capable.

I could not agree more having gone through the process of getting an IFR approved GPS system. It is a very big no no until you go through all the hoops to get the approval.

Fly safe and don't file /G until you get the approvals.

John J

 

[poadeleted20]

That said, I was truckin' on back to SBY from HGR last Friday IFR to get better ADIZ handling when Potomac Approach asked if was GPS-equipped. "Just a handheld," I said. "Can you go direct GRACO intersection?" "I can if you give me a vector." "Fly present heading vectors to GRACO then direct SBY." Last vector he gave me, but I was legal all the way.

 

[Ed Guthrie]

That said, I was truckin' on back to SBY from HGR last Friday IFR to get better ADIZ handling when Potomac Approach asked if was GPS-equipped. "Just a handheld," I said. "Can you go direct GRACO intersection?" "I can if you give me a vector." "Fly present heading vectors to GRACO then direct SBY." Last vector he gave me, but I was legal all the way.

We could argue whether you were legal before the potential COM failure. Absoltuely no doubt you would have been illegal after the COM failure.

 

[Don Jones]

That brings up another question, have the requirements changed any for IFR
certified installs? The process to field approve the thing when I did it a couple of years ago even for VFR use was challenging to say the least. I heard later the process had been simplified by the FAA to encourage more people to go to GPS, is this true?
I guess I will have to just bite the bullet and let the avionics shop get the
thing IFR certified one of these days.

To answer a couple of questions the unit is a Garmin 300XL and does have internal CDI and annunciators, however they do not meet IFR requirements for some reason.

Thanks for the answers
Don

 

[gismo]

That brings up another question, have the requirements changed any for IFR
certified installs? The process to field approve the thing when I did it a couple of years ago even for VFR use was challenging to say the least. I heard later the process had been simplified by the FAA to encourage more people to go to GPS, is this true?
I guess I will have to just bite the bullet and let the avionics shop get the
thing IFR certified one of these days.

To answer a couple of questions the unit is a Garmin 300XL and does have internal CDI and annunciators, however they do not meet IFR requirements for some reason.

The process has been simplified, at one point each and every /G installation had to be flight tested like a Rho-Theta RNAV, but AFaIK that's no longer required for GPS. BTW there's an advisory circular on the subject you can download from the FAA website.

WRT the 300XL, I suspect the model has to be approved for stand alone installation. I don't belive that an internal CDI display is required, but the annunciators must be displayed all the time (not something that can be selected by the user).

 

[Don Jones]

The process has been simplified, at one point each and every /G installation had to be flight tested like a Rho-Theta RNAV, but AFaIK that's no longer required for GPS. BTW there's an advisory circular on the subject you can download from the FAA website.

WRT the 300XL, I suspect the model has to be approved for stand alone installation. I don't belive that an internal CDI display is required, but the annunciators must be displayed all the time (not something that can be selected by the user).

Thats interesting, I went through all the flight testing and documentation of the flight test. The unit itself is TSO129 A1 certified, but Garmins original certification included an external CDI and annunciator panel and since this is a follow on installation mine would have required it as well. I heard it had some to do with pilots line of sight and that the internal CDI is too small(total nonsense) I am going to call my avionics guy and see what he thinks it will take to get it certified IFR. Seems silly to have the thing and not be able to use it as primary nav, even though I always back it up with VOR nav anyway.
Thanks for the answers
Don

 

[poadeleted20]

We could argue whether you were legal before the potential COM failure. Absoltuely no doubt you would have been illegal after the COM failure.

Fortunately, I know how to use VOR and DME to navigate point-to-point to a radial/DME fix, and have been certified in my ability to do so. Had I not had an operating DME aboard, I could not have accepted this clearance.

 

[Ed Guthrie]

Fortunately, I know how to use VOR and DME to navigate point-to-point to a radial/DME fix, and have been certified in my ability to do so. Had I not had an operating DME aboard, I could not have accepted this clearance.

In this particular example (Part 91 IFR flight) the FAA doesn't give a rat's pitutti what you learned, or where, or who supposedly "certified" you, unless the FAA did the IFR certifying of both the technique and the box(es). Neither of those criteria being true in this case. If you wish to legally area navigate under IFR the FAA wants an FAA approved, IFR certified area navigation box for legal compliance with 91.205(d)(2) and 91.185(c)(1)(ii).

If you wish to argue the point, perhaps you could point the audience to the area navigation equipment certification requirements for VOR + DME IFR area navigation? I'm sure a few equipment manufacturers would love to be so enlightened as the market for the boxes would expand greatly. Seems King, Narco et al have for many years missed out on telling folks that they can legally fly IFR area navigation with just VOR + DME.

 

[Henning]

We could argue whether you were legal before the potential COM failure. Absoltuely no doubt you would have been illegal after the COM failure.

Not necessarily, as long as he has an approved method to find the intersections, he is perfectly fine to take that clearance. GPS isn't the only method, I was finding Intersections using VORs, ADFs and DME before GPS came around and still do it today.

 

[Ed Guthrie]

Not necessarily, as long as he has an approved method to find the intersections, he is perfectly fine to take that clearance. GPS isn't the only method, I was finding Intersections using VORs, ADFs and DME before GPS came around and still do it today.

See my comments to Ron and then fill in the blanks as best you can. What you were doing (and Ron) was flying somewhat randomly to the fix illegally without drawing attention to yourself and therefor not getting busted, which is significantly different from legally flying direct to the fix.

FWIW, assume the intersection is on a victor airway west of the VOR. Assuming the aircraft is not IFR approved area navigation equipped you can't legally accept a heading "vectors direct BULOX", but you can accept the exact same heading "vectors to intercept Victor xx west of NOWHERE". Both vectors are going the same place, but one is legal while the other isn't (for the non-area navigation equipped aircraft). The good controllers know this trivia and will alter the clearance accordingly.

 

[waldo]

I know this has been covered extensively on the other board, but I would like a clarification. I have a panel mount IFR certified GPS, but it is not an IFR certified installation since it lacks an annunciator panel and external CDI. Can I file /G? I heard somewhere I could but I want to know for sure.
Inquiring minds want to know the real truth.
Don

Yes the aircraft must have an IFR certified GPS and the GPS Flight Manual Supplement must be on the aircraft. Some GPS units (older) had a CDI built in. They do not require a seperate CDI indicator installed. However, I think these older GPS units are IFR Enroute approved only, and not IFR approach approved. Someone correct me if I'm wrong .

 

[Henning]

See my comments to Ron and then fill in the blanks as best you can. What you were doing (and Ron) was flying somewhat randomly to the fix illegally without drawing attention to yourself and therefor not getting busted, which is significantly different from legally flying direct to the fix.

FWIW, assume the intersection is on a victor airway west of the VOR. Assuming the aircraft is not IFR approved area navigation equipped you can't legally accept a heading "vectors direct BULOX", but you can accept the exact same heading "vectors to intercept Victor xx west of NOWHERE". Both vectors are going the same place, but one is legal while the other isn't (for the non-area navigation equipped aircraft). The good controllers know this trivia and will alter the clearance accordingly.

Wow, then Ive been receiving and accepting illegal clearances for a long time. I assumed if the controller issued it, I was legal to comply as long as I didn't see a safety of flight issue. I have been issued "Climbing left turn to 2500 fly heading 200 vectors (what is now)PADDR and hold EFC 0900 for ILS 30" many times waiting for the marine layer to lift enough to make it into LGB. I have never flown with a functioning area nav system of any kind.

 

[poadeleted20]

Ed's right -- I should have asked for a vector to join V93 near GRACO, then direct SBY VOR, since that's a clearance with which I could legally comply with the equipment on board.

 

[Ed Guthrie]

Wow, then Ive been receiving and accepting illegal clearances for a long time.

Don't feel bad--it is a common trap into which many, many pilots blunder. Before I started flying my IFR legal VOR/DME RNAV equipment I probably stepped in the trap once or twice myself.

I assumed if the controller issued it, I was legal to comply as long as I didn't see a safety of flight issue.

Never so unless the clearance is legal for you. IOW, ATC is not required to determine if the clearance is legal for the aircraft & pilot--that's the pilot's job. ATC could clear you for the Cat II ILS, but unless you and the aircraft are CAT II equipped and qualified you can't go there. Ron L's favorite example on this issue is the tower clearing a pilot for a low inverted pass down the runway. Tower my clear you, but the clearance is illegal for you to accept.

I have been issued "Climbing left turn to 2500 fly heading 200 vectors (what is now)PADDR and hold EFC 0900 for ILS 30" many times waiting for the marine layer to lift enough to make it into LGB. I have never flown with a functioning area nav system of any kind.

My favorite pet peeve these days is ATC asking, "Are you /G?" The inevitable rest of the conversation:

Pilot - "Negative, but we have a VFR GPS"
ATC - "Can you navigate direct PODNK?"
Pilot - "Affirmative."
ATC - "Cleared direct PODNK, then as previously cleared."

One of the days a local FSDO inspector will pull the TRACON tapes, grab a box of Dunkin' Donuts and a huge cup of coffee, done headphones, and then kick back listening to yesterday's ATC tapes while spilling powdered sugar and coffee on his tie. He'll have a set of form letter enforcement actions on his left which he will pick up one at a time and note the aircraft registration and time of day, and that he just heard a 91.205 violation. End of the day the huge stack of blank form letters on the left will be a huge stack of proposed enforcement actions on the right.

What the pilot should have said is, "Negative, but we can take a vector to intercept victor XX north/east/west/south of NOWHERE VOR." The same applies to your departure & hold example.