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1. 08:57 PM - Re: 91.205 (WAAS) ()
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| Subject: | Re: 91.205 (WAAS) |
1/3/2007
Hello Wayne, Good to hear from you.
You wrote: "I've heard it said more than once that an amateur-built plane
cannot be flown IFR with just a GPS. It must also have the traditional VOR
and ILS (when needed) receivers on board.
They cite 91.205 and the requirement to have "...equipment on board
appropriate to the ***ground-based*** navaids to be used. Why do you think
experimentals are held to that when the standard certificated aircraft
(Mooneys, Pipers, etc) are now flying with WAAS GPSs
and nothing else? Why must me have the crappy, out-dated stuff on board
when the new avionics suites in the newer planes do not?"
I do not agree with the statement "It (an ABEA (Amateur Built Experimental
Aircraft)) must
also have the traditional VOR and ILS (when needed) receivers on board."
Here is why I do not agree with that statement:
A) "The GNS 400/500 series have earned the FAAs TSO C146a Gamma-3
certification, which enables pilots to fly Lateral-Precision with Vertical
(LPV) guidance approaches and receive GPS navigation via the Wide Area
Augmentation System (WAAS)."
B) "Garmins GNS 400W/500W series meets the FAAs highest level of
certification for WAAS navigation. The units utilize satellite-based navaids
for precise lateral and vertical approach guidance similar to Instrument
Landing System (ILS) operations without the need for ground-based navaids
of any kind."
C) "The WAAS system improves the accuracy, reliability and integrity of the
GPS signal. GPS-WAAS navigators that meet FAAs WAAS regulations may be used
for sole means of navigation* for all phases of flight, including en route
through precision approach at airports."
These paragraph A, B, and C quotes are from a Garmin press release, see copy
below.
D) The WAAS system does involve ground facilities despite what Garmin says
in B above. See http://gps.faa.gov/programs/index.htm for a description of
the WAAS that incorporates both WRS (Wide area Reference Stations) and a WMS
(WAAS Master Station) which are facilities located on the ground.
Therefore an ABEA equipped with either a GNS 400W/500W, but no VHF
navigation equipment would be in compliance with its Operating Limitations
which requires compliance with FAR 91.205 (b), (c), and (d) when operating
IFR. Specifically the WAAS navigation equipment of that aircraft would be in
compliance with 91.205 (d) (2) which requires "navigational equipment
appropriate to the ground facilities to be used."
I intend to upgrade my GNS 430 to 430W configuration, but I certainly don't
intend to fly IFR if my VHF nav equipment is not operating. Obviously when
flying an ILS approach one must have funcioning localizer and glideslope
equipment on board. And similarly when flying a published approach that
requires GPS / WAAS equipment then that equipment must be on board and
functioning.
OC -- The best investment we will ever make is in gathering knowledge.
------------------------ GARMIN PRESS RELEASE FOLLOWS --------------
November 9, 2006
Garmin Receives WAAS Certification for GNS 400W/500W series
OLATHE, Kansas/November 9, 2006/PR Newswire Garmin International, a unit
of Garmin Ltd. (Nasdaq: GRMN), today announced the achievement of a major
aviation milestone at the Aircraft Owners and Pilots Association (AOPA) Expo
in Palm Springs, CA. The GNS 400/500 series have earned the FAAs TSO C146a
Gamma-3 certification, which enables pilots to fly Lateral-Precision with
Vertical (LPV) guidance approaches and receive GPS navigation via the Wide
Area Augmentation System (WAAS). The FAA also granted AML (approved model
list) STC approval allowing the 400W/500W equipment to be installed on over
980 popular makes and models of aircraft. The GNS 400/500W series joins the
G1000 and GNS 480 in providing WAAS enabled navigation for aircraft. Garmin
currently offers more WAAS solutions than any other avionics provider.
"This is a great day for Garmin and the aviation industry," said Gary
Kelley, Garmins vice president of marketing. "Since the FAA commissioned
WAAS in 2003, there has been an enormous demand for WAAS certified equipment
in the marketplace. We are pleased to announce that all 75,000 Garmin GNS
400/500 series products currently in the field can upgrade to WAAS. We
expect the number of WAAS equipped aircraft to increase quickly, and pilots
will be able to operate to and from airports that would otherwise be
unavailable to them in marginal weather."
Thanks to the certification and AML STC approval, owners of Garmins popular
GNS 400/500 series panel-mount avionics will be able to upgrade their
products to meet the FAAs WAAS standards* without a field approval**. These
upgrades include 5 Hz position updates, faster map redraws, fully coupled
and guided procedure turns and holding patterns, and increased XM weather
content. Pilots will also experience significantly enhanced functionality
because of the WAAS LPV, LNAV/VNAV, LNAV+V, and LNAV approach capabilities.
Garmins GNS 400W/500W series meets the FAAs highest level of certification
for WAAS navigation. The units utilize satellite-based navaids for precise
lateral and vertical approach guidance similar to Instrument Landing
System (ILS) operations without the need for ground-based navaids of any
kind. The Gamma-3 level of certification lets pilots fly the FAAs new LPV
approaches. The FAA has already published over 600 LPV and 5,500 WAAS
approach procedures.
The WAAS system improves the accuracy, reliability and integrity of the GPS
signal. GPS-WAAS navigators that meet FAAs WAAS regulations may be used for
sole means of navigation* for all phases of flight, including en route
through precision approach at airports. With WAAS LPV approaches, pilots
will have stabilized lateral and vertical navigation and will be able to
navigate as low as 200 feet above the runway end under instrument flight
rules.
Garmins panel mount avionics have been installed on nearly three-fourths of
all U.S. single and twin-engine piston and turbine aircraft retrofitted
since 2000. The company strives continually to raise-the-bar in the avionics
industry, and two years ago at the 2004 AOPA Expo Garmins GNS 480 was the
first GPS navigator in the industry to earn a TSO C146a Gamma-3
certification.
Garmin expects deliveries of the new GNS 430W and GNS 530W to begin in
about 30 days with upgrades beginning in January 2007. Upgrades are
available for a suggested retail price of $1,500. Pilots who do not
currently own Garmin 400/500 series equipment and are in the process of
upgrading their avionics, will be able to purchase new GNS 430W and GNS 530W
units for $10,750 and $16,495, respectively. Visit www.garmin.com for
additional information or a complete list of authorized Garmin dealers.
*Due to the TSO limitation in conjunction with the AFMS limitation, Garmins
GNS 400/500 series navigators will not be certified as a "primary means" of
GPS navigation until after customers install a new software version. Garmin
expects to issue a Service Bulletin in the first quarter of 2007 issuing the
software. The software will be updated via the 400/500W data loader card.
This required software update is expected to be available in the first
quarter of 2007.
**The AML STC data is intended to provide complete FAA approved data for a
large subset of CAR3/FAR23 aircraft; however, if the aircraft does not
pre-qualify for the AML STC standards, additional means of airworthiness
approval will be required.
------------------------ END OF GARMIN PRESS RELEASE ------------------
----- Original Message -----
From: "Hicks, Wayne" <wayne.hicks@zeltech.com>
Sent: Wednesday, January 03, 2007 3:02 PM
Subject: 91.205
> OC:
>
> Happy New Year to you!
>
> Can you help me to understand something? I've heard it said more than
> once
> that an amateur-built plane cannot be flown IFR with just a GPS. It must
> also have the traditional VOR and ILS (when needed) receivers on board.
> They cite 91.205 and the requirement to have "...equipment on board
> appropriate to the ***ground-based*** navaids to be used."
>
> Why do you think experimentals are held to that when the standard
> certificated aircraft (Mooneys, Pipers, etc) are now flying with WAAS GPSs
> and nothing else? Why must me have the crappy, out-dated stuff on board
> when the new avionics suites in the newer planes do not?
>
> I got asked this question from my Cozy builders group. About the only
> answer I can come up with is (1) the manufacturer proved the nav
> capabilities of the airplane's capabilities as part of its type
> certification process; and (2) The FAA is not in the business of
> certifying
> the on-board nav capabilities of everyone's home-built airplane. So the
> FAA
> makes us use their nav system.
>
> How close am I?
>
> ===================
> L. Wayne Hicks
> Senior Engineer
> Zel Technologies, LLC
> 757-325-1282 phone
> wayne.hicks@zeltech.com
> http://www.zeltech.com
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