Log your GPS database updates

dmccormack said:
For a VFR Database, Ron?

Check again.
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I don't always update my VFR database, but when I do I drink Dos Equis and I log the dang thing.

Dan I think most are in agreement with you that it is silly to require logging of a VFR DB update, but the reg just says if you update the GPS DB you gotta log it. It says nothing about what kind of GPS you have.
 
Here we go again with another Ron Levy change of subject matter...

:rofl:

So let me bring it back to the actual point of this thread:

There is NO REQUIREMENT to update VFR GPS Databases.

None, not one, no where, in any reg, period.

IF you decide to update the DB, it would be anal-retentive wise to log it as a matter of habit as you should log any change to the airframe (and I said as much many posts ago).

Even though it's a stupid requirement since we're merely updating VFR data, and data is constantly changing (are we logging flight timer increments? bread crumbs? Flight plan waypoints? XM weather updates?)

HOWEVER, if you choose not to log the VFR GPS DB update, and fly another five years behind your trusty Garmin GNC-250XL VFR GPS, and break no other rules, you're probably safe from the feds calling you in for a talk. If you break a rule and they wanna fry you -- they will, VFR GPS updates logged or not.

In the OP case -- as we all suspected and later learned -- this was a 135 op with other issues. They added this gem 'cause they could.

The rules are different for IFR GPS since we're depending on that data for safety of flight. We aren't (and should not be) depending on a VFR GPS for safety of flight. If you are, you're dumb.


That make it plain enough? :rolleyes2:
 
dmccormack said:
There is NO REQUIREMENT to update VFR GPS Databases.
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I don't think anyone was arguing against that (the way I read the thread anyway).

There's no requirement to update an IFR database either for that matter.

There are requirements stating what you may or may not do under IFR with an expired database.
 
COFlyBoy said:
I don't think anyone was arguing against that (the way I read the thread anyway).

There's no requirement to update an IFR database either for that matter.

There are requirements stating what you may or may not do under IFR with an expired database.
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Yep, but threads wander.

Shocker.
 
Ron Levy said:
I'm not implying that -- the FAA is saying that.
...and Appendix A to Part 43 tells us what is defined as "preventive maintenance," and adding oil (as opposed to an oil change which requires removing, replacing, and safety-wiring the drain plug), isn't on that list.
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Appendix A
(c) (6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.

That is considered preventive maintenance. Lubrication that doesn't require disassemble. Unless that disassemble is only removal of nonstructural items such as cover plates, cowlings and fairings. It doesn't mention safety-wiring on the drain plug.

COFlyBoy said:
I don't always update my VFR database, but when I do I drink Dos Equis and I log the dang thing.
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I think you just won the internet.
 
The AC has been updated and a log book entry is no longer required.
 
Here is the 2012 amendment to the FAR, found in Vol. 77 No. 230 of the federal register at page 71089, and effective as of January 28, 2018:
https://www.govinfo.gov/content/pkg/FR-2012-11-29/pdf/2012-28845.pdf

On page 71092 (page 4 of the linked PDF), you will find this language:

Several commenters, including AOPA and NetJets, were concerned about the requirement for the pilot to record each update in a maintenance logbook. AOPA expressed concern that the NPRM proposed a requirement that would create a second recordkeeping requirement and that the return to service maintenance entry required by § 43.7 would need to be completed by ‘‘qualified personnel.’’ NetJets recommended that the FAA specifically state in the final rule preamble that no aircraft maintenance entries or signatures are required when pilots perform aeronautical database updates. We have considered the comments and agree that it is unnecessary for the pilot to make a record of the update. Recordkeeping requirements for the pilot have been eliminated. The current regulations do not require pilot-owners to record each update in a maintenance logbook, and the absence of such a requirement has not been problematic.
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(Emphasis supplied.)

I don't know what AC or chief counsel opinions people may have been referring to in this thread back in 2011 or now in 2019, but the rule itself appears to have been kept intact since the 2012 amendment. Here is the eCFR link to 14 CFR 43.3:
https://www.ecfr.gov/cgi-bin/text-i...&mc=true&node=pt14.1.43&rgn=div5#se14.1.43_13

It says:
(k) Updates of databases in installed avionics meeting the conditions of this paragraph are not considered maintenance and may be performed by pilots provided:

(1) The database upload is:

(i) Initiated from the flight deck;

(ii) Performed without disassembling the avionics unit; and

(iii) Performed without the use of tools and/or special equipment.

(2) The pilot must comply with the certificate holder's procedures or the manufacturer's instructions.

(3) The holder of operating certificates must make available written procedures consistent with manufacturer's instructions to the pilot that describe how to:

(i) Perform the database update; and

(ii) Determine the status of the data upload.
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(Emphasis supplied.)

My take, speaking as some guy on the internet: Someone from the FAA went off his mood stabilizer pills back in 2011, ramp checking and writing up pilots who updated their GPS databases without logging the "maintenance" they had done. That led to this thread and other upheavals. The FAA promptly realized that their attempt to make it easy to update databases (a good thing) with minimal changes to the FARs (also generally a good thing) had unintended consequences, and they fixed it by just saying that database updates aren't maintenance at all.
 
I hope anyone who was violated had their record cleared.
 
poadeleted21 said:
The problem with these nit-picky regs IMHO is that folks will ignore them and it starts a culture of picking and choosing what regs to follow. My 2 cents.
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People start picking and choosing because the FAA can't sift the trivial from the essential. They tend to treat them with equal import - and everything isn't of equal import.

And eff the "good attitude" - We should expect professional demeanor from a Fed, and one that alters his/her actions based on perception of "attitude" is a petty jerk. They aren't attitude police - show up, ask for what you want, and if I don't smile, offer you a beer, or happen to roll my eyes, tough sh*t.

In turn, I'll comply with the letter of the law, not curse or berate, and offer no more info or documentation than the regs demand. If that doesn't suit, then he/she needs an attitude adjustment.
 
I've seen (perhaps on here?) K(1)iii debated quite heavily.

While many feel removing the screw holding the port cover in place on the GPS doesn't break the "no tools" portion of the rule, there are questions around whether a computer with a card reader and Garmin (or other) software installed counts as "specialized tools." Not saying I agree with that assessment but it is something I've heard suggested before.
 
apr911 said:
I've seen (perhaps on here?) K(1)iii debated quite heavily.

While many feel removing the screw holding the port cover in place on the GPS doesn't break the "no tools" portion of the rule, there are questions around whether a computer with a card reader and Garmin (or other) software installed counts as "specialized tools." Not saying I agree with that assessment but it is something I've heard suggested before.
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On mine I use an SD card, nothing specialized about that. SD cards are used for plenty of non aviation uses, same with computers, card readers and even the web based tool which downloads and flashes the drive with some code.

My suggestion is people who feel it’s specialized should keep a special logbook to fill out when doing their special maintanence.
 
OkieAviator said:
On mine I use an SD card, nothing specialized about that. SD cards are used for plenty of non aviation uses, same with computers, card readers and even the web based tool which downloads and flashes the drive with some code.

My suggestion is people who feel it’s specialized should keep a special logbook to fill out when doing their special maintanence.
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Well its more that the FAA doesn't really specify what classifies as "specialized tools" and/or "complex assembly." Prevalence doesn't necessarily mean much, after all, many people have wrenches/socketwrenches doesn't mean they can go cranking away on their engine but most people dont have the equipment to mount and balance a tire (nor would they likely no how to use it and what they were doing if they had access to one) yet replacing landing gear tires is permitted.

The use of the computer, card reader and SD card are all straight forward enough but the software is specifically written for the express purpose of getting the GPS files and flashing the card with the GPS image files. It serves no other purpose and therefore is "specialized software" though I dont particularly subscribe to the GPS updates requiring "specialized tools" recognizing the FAA probably means specialized in the form of "requiring or involving detailed and specific knowledge or training" and not "designed for a particular purpose."
 
apr911 said:
Well its more that the FAA doesn't really specify what classifies as "specialized tools" and/or "complex assembly."
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They don't need to, the definition is found within the English language. Any subjectivity is only for those trying to over complicate it or try and 'get someone' on something. If I was having this conversation with a fellow pilot on the field I would tell them to go ahead and do what they feel they need to do. Hire an A&P, log it, track it with a tattoo... whatever helps them. I personally don't and won't log my updates.

On the software component it isn't 'specialized' and serves more purposes then flashing aviation SD Cards (Branding as FlyGarmin, but no different than their other update packages). In addition to that it's a guided process so unless you can't read you don't need training.
 
OkieAviator said:
I would tell them to go ahead and do what they feel they need to do. Hire an A&P, log it, track it with a tattoo... whatever helps them. I personally don't and won't log my updates.
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I agree, both with the sentiment that they should do what they feel they need to do and that I personally dont log my GPS updates.

OkieAviator said:
They don't need to, the definition is found within the English language.
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I have to disagree with this. I absolutely hate the "well its plain English" explanation as if that makes the ambiguity go away. Language is a common framework but it is inherently interpretative and fed by our own experiences. What I find to be an easy task may well be a complex convoluted process to someone else. Similarly an automobile mechanic probably wouldn't find the engine of an airplane all that difficult to work with, in some ways its less complex (less computer management) but in others it can be more complex dependent on the relative experience of the mechanics (adjusting a carburetor, especially without experience with carburetors vs adjusting fuel injectors and the computer managed fuel flows).

Perhaps I'm too analytical in this regard and I dont mean to direct my ire towards you but every conversation in which this sort of language ambiguity comes up seems to have someone putting forth the idea "its plain english" as if their interpretation is the one everyone should have. If it were "plain english" there would never be any such question raised and there would be no need whatsoever for the numerous letters of interpretation issued by FAA Chief Counsel.

That's all I'm going to say on the topic as I've found it less than productive to engage further on the topic of "its plain english."
 
apr911 said:
I have to disagree with this. I absolutely hate the "well its plain English" explanation as if that makes the ambiguity go away. Language is a common framework but it is inherently interpretative and fed by our own experiences.
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Feel free to bow out, however you went ahead and put an additional adjective onto my statement. I didn't use the word 'plain', I'm very aware of the interpretation issues with judicial and regulatory documents. There are several entire career paths that take a statement and write out full dissertations on the presumed meaning (As you mentioned LOIs). The main point I was trying to make is I'm going to take a regulation at face value, make my own determination on intent and then move forward. I'm not going to be paralyzed waiting for the government to tell me what to do exactly. I'll explain or defend my stance if it becomes an issue, not going to try to speculate on the intent.
 
OkieAviator said:
Feel free to bow out, however you went ahead and put an additional adjective onto my statement. I didn't use the word 'plain', I'm very aware of the interpretation issues with judicial and regulatory documents. There are several entire career paths that take a statement and write out full dissertations on the presumed meaning (As you mentioned LOIs). The main point I was trying to make is I'm going to take a regulation at face value, make my own determination on intent and then move forward. I'm not going to be paralyzed waiting for the government to tell me what to do exactly. I'll explain or defend my stance if it becomes an issue, not going to try to speculate on the intent.
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Now that I can agree with pretty much in full.
 
I have a hard time convincing myself that the FAA had software installed on a general-purpose computer in mind when they wrote "tools and/or special equipment." In my understanding of the English language, a computer is "equipment," but a general-purpose computer is not "special equipment." The same goes for the SD card, which is a general-purpose and widely-used device that is used to transfer data from one device to another. As for the word "tool," if one uses the widest possible interpretation of the word, then the SD card, the computer, and the software could all be considered tools, but if that was what the FAA had in mind when they wrote the regulation quoted above, it would render that regulation meaningless. Can you think of any way at all that a GPS database could be updated without using a tool if the term were being that broadly interpreted? I can't. I'm not a lawyer, but my understanding is that judges don't like to adopt interpretations of a regulation that render it meaningless.

It doesn't require any tool to remove and insert the programmed SD chip into many of the newer GPSes. I think the FAA's intention was to allow pilots to do that. That's the only interpretation I can think of that allows paragraph (k) to serve any purpose at all.

FAA regulations are riddled with ambiguities in language from start to finish. One of the ways of dealing with that is to ask the FAA Chief Counsel's office for an interpretation, but we've gotten saddled with some pretty silly and sometimes onerous interpretations by going that route, so please don't anyone write the Chief Counsel about this. If pilots are not actually receiving violations for programming and inserting SD cards, using software that database suppliers freely provide to users, then I say we are better off leaving well enough alone.

For those who are AOPA members, I asked this question on their forum a few years ago and received a similar answer:

http://forums.aopa.org/showthread.php?t=97458
 
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Palmpilot said:
Can you think of any way at all that a GPS database could be updated without using a tool if the term were being that broadly interpreted?
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Sure, you could receive a pre-programmed, tested and write-locked SD card from Garmin.

I cant tell you the number of times I've had image files fail to write properly to SD cards and other media. I've seen it all from incomplete data to data corruption to a complete lack of functionality in the card. Granted, I write image files more than most being in IT but the point is, it's not always perfect.

Also if the term "tool" were being interpreted that broadly, the GPS could still be updated by a qualified mechanic so its not like you wouldn't be able to update the database at all, just that updating the database would become much more involved since you personally cant do it.
 
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