Today's Message Index:
----------------------
1. 09:49 AM - Re: GRT GPS TSO ()
2. 10:52 AM - GRT GPS TSO ()
3. 11:41 AM - ABEA and TSO's ()
4. 12:21 PM - Re: ABEA and TSO's (Doug20310)
5. 02:13 PM - Re: GRT GPS TSO ()
6. 07:33 PM - Re: Re: GRT GPS TSO (W J R HAMILTON)
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1/9/2007
Hello Bret, Continuing our dialogue.
1) You wrote: "If I get called out on the carpet for a non-TSO'd GPS, what
would they say
about my non-TSO'd TruTrak AP, Ray Allen trim system, GRT AHRS/Magnetometer,
HID homegrown landing lights, LED nav lights, etc?"
I believe that IFR / Night equipment for ABEA's falls into one of the
following categories:
1A) Purely optional equipment installed at the desire of the builder with no
existing regulatory requirement.
1B) Equipment required by FAR 91.205 (b), (c), and (d) because of wording in
the aircraft's Operating Limitations.
1C) Equipment required by FAR 91.205 (b), (c), and (d) because of wording in
the aircraft's Operating Limitation that is identified as needing to be
"approved" in those paragraphs.
1D) Equipment required by other paragraphs within the FAR's that would apply
to all aircraft, both type certificated with standard airworthiness
certificates and ABEA's with special airworthiness certificates.
1E) Equipment required by the AIM for certain types of operations that would
apply to all aircraft, both type certificated with standard airworthiness
certificates and ABEA's with special airworthiness certificates.
2) Your non-TSO'd TruTrak AP, Ray Allen trim system, GRT AHRS/Magnetometer,
HID homegrown landing lights and other equipment of that ilk would fall into
category 1A above and should generate no FAA criticism because it is not
TSO'd.
3) Your LED nav (position) lights would fall into category 1C above. See
91.205 (c), (2). If your initial ABEA airworthiness inspector issues the
aircraft a special airworthiness certificate he has, by implication,
"approved" those position lights in the name of the FAA Administrator (see
FAR 1.1). If he refuses to issue the certificate and demands to see TSO
markings because the regulations require it, he is wrong. If he refuses to
issue the certificate and demands to see either TSO markings or test results
showing that the lights meet FAR Part 23 position light standards, that is
within his prerogative as an inspector.
4) If you had only a non TSO'd GPS aboard and performed a specific operation
that the AIM required a TSO approved GPS for then you would not be in
compliance with 1E and may be subject to a charge of careless or reckless
operation (see FAR 91.13).
5) You wrote: "My understanding is that before flight into the national air
system, under
IFR, the pilot/builder of the OBAM aircraft must determine and document via
flight testing that the aircraft and it's systems meet the requirements for
IFR flight, night flight, etc."
This is certainly common sense. I would be interested in seeing some
regulatory basis for the above. The sources that I am aware of that cover
specific ABEA requirements for IFR and night flight are the Operating
Limitations for that aircraft and the references contained therein including
FAR 91.319.
FAR 91.319 (d), (2) reads "Operate under VFR day only, unless otherwise
specifically authorized by the Administrator."
The Operating Limitations will contain these words: "After completion of
Phase I flight testing, unless appropriately equipped for night and/or
instrument flight in accordance with 91.205, this aircraft is to be operated
under VFR, day only."
If the aircraft meets the "appropriately equipped" criteria it is considerd
by the FAA to have been given the Administrator's specific authorization to
fly at night and under IFR. What we have been discussing is what constitutes
"appropriately equipped".**
OC -- The best investment we will ever make is in gathering knowledge.
**PS: It is interesting to note that if the aircraft is given authorization
for aerobatic flight in the Operating Limitations that those maneuvers must
be specifically tested and documented in the aircraft's logbook.
PPS: You wrote: "This is a really interesting topic and I truly respect your
opinions.
It is evident you have a good understanding of these issues."
I appreciate your kind words.
----- Original Message -----
From: "Bret Smith" <smithhb@tds.net>
Sent: Monday, January 08, 2007 4:46 PM
Subject: Re: GRT GPS TSO
>I see your point, and have a GNS 430 as my primary GPS. I want the GRT IFR
>GPS as a secondary GPS (hard to beat getting an IFR WAAS GPS for $750.00).
>
> If I get called out on the carpet for a non-TSO'd GPS, what would they say
> about my non-TSO'd TruTrak AP, Ray Allen trim system, GRT
> AHRS/Magnetometer, HID homegrown landing lights, LED nav lights, etc?
>
> My understanding is that before flight into the national air system, under
> IFR, the pilot/builder of the OBAM aircraft must determine and document
> via flight testing that the aircraft and it's systems meet the
> requirements for IFR flight, night flight, etc.
>
> Bret
>
> PS, This is a really interesting topic and I truly respect your opinions.
> It is evident you have a good understanding of these issues.
Message 2
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1/9/2007
Hello Bill,
1) You wrote: " In some instances the regs require that a piece of equipment
MUST MEET TSO
STANDARDS. This is the case with transponders. In other instances the
equipment MUST BE TSO'd. This is the case with IFR GPS units."
Both TSO-145A and TSO-C146A dealing with IFR GPS units contain the following
paragraph (MPS means Minimum Performance Standards):
"g. Deviations. The FAA has provisions for using alternative or equivalent
means of compliance to the criteria set forth in the MPS of this TSO.
Applicants invoking these provisions shall demonstrate that an equivalent
level of safety is maintained and shall apply for a deviation per 14 CFR
21.609"
2) TSO-C129a is an older TSO dealing with IFR GPS units and does not contain
specific alternate compliance words within it as is the case with more
current FAA TSO's, but here is a quote from the current AIM, note the use of
the word "equivalent":
"g. Equipment and Database Requirements.
1. Authorization to fly approaches under IFR using GPS avionics systems
requires that:
(a) A pilot use GPS avionics with TSO- C129, or equivalent, authorization in
class A1, B1, B3, C1, or C3; and......"
3) You wrote: "If simply meeting the TSO requirements is adequate, why
should a
manufacturer "go to the expense and effort"?"
My point exactly. Simply meeting some of the TSO requirements is not
adequate to fulfill the intent of the FAA TSO requirements.
GRT implies that they are completely fulfilling the FAA TSO intent by
writing: "The new RAIM-equipped version provides integrity monitoring and 5
updates per second to meet the requirements of IFR GPS TSO C129 and C146."
The equipment must either be TSO'd in accordance with the provisions of FAR
Part 21 Subpart O or FAA deviation approval from the TSO in accordance with
paragraph 21.609 must be obtained. Neither one of these are easy actions to
take and there is no indication in the GRT statement posted that either
action has been taken. Hence my suspicion of misleading weasel wording.
OC -- The best investment we will ever make is in gathering knowledge.
Time: 09:35:15 AM PST US
From: "Bill Denton" <bdenton@bdenton.com>
Subject: RE: AeroElectric-List: GRT GPS TSO
"A piece of equipment either meets the full TSO requirements and is marked
TSO compliant or it is not TSO'd."
True, but not necessarily the point...
In some instances the regs require that a piece of equipment MUST MEET TSO
STANDARDS. This is the case with transponders.
In other instances the equipment MUST BE TSO'd. This is the case with IFR
GPS units.
You mentioned, "...manufacturers who have gone to the expense and effort of
obtaining TSO approval for a piece of equipment..."
If simply meeting the TSO requirements is adequate, why should a
manufacturer "go to the expense and effort"?
Message 3
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1/9/2007
Hello Ernest, Thanks for your input.
1) You wrote: "That, to me, is a convoluted way of thinking. "There's no
law against
it, but we don't like what you did." Is that any way to run a country!?
The AIM is not regulatory in nature. OK, then when consideration of fines
begin, it is immaterial."
This may not be the best way to run a country, but it is the system we have
come up with over the years and I don't expect it to change real soon.
We have formal laws passed by congress (Title 14), we have regulations
written by bureaucrats to implement those laws (FAR's), and we have non
regulatory documents (Advisory Circulars, AIM, FAA Orders, etc.) to help
interpret and implement those regulations. Then we have those same
bureacrats (ninety percent of whom seem to be non-pilot lawyers)
interpreting and enforcing those regulations.
And I can assure you that if you are standing in front of an NTSB judge
charged with violation of FAR 91 Careless and Reckless Operation because you
violated a provision of the AIM that a potential fine and certificate action
is not immaterial.
2) You wrote: "If the non-TSOed unit operated as advertised for several
years, but then went
flaky enough to cause and incident, it would be no different than a TSOed
unit going tits-up. How an inspector 'feels' about it is smoke in the
wind."
The above is not an accurate description of the issue. The issue was a pilot
knowingly using a non TSO'd unit to perform an IFR maneuver that the AIM
said required a TSO'd unit (or equivalent) and a deviation or violation
occurred. I wrote that the pilot could be subject to punishment for such a
violation of the AIM. This is true.
3) You wrote: "If non-TSOed equipment performs just as well at half the
price, only
lacking the reams of paperwork required for the bureaucratic blessing, why
wouldn't the choice be equally clear? The builder has done the
pre-requisite homework, after all?"
If the builder knowingly installs and uses non TSO'd (or equivalent)
equipment to perform an IFR operation that the FAA intends should only be
performed by TSO'd (or equivalent) equipment that builder is taking a risk.
His risk could result in:
a) No harm.
b) Embarrassment.
c) A fine.
d) Loss of certificate
e) Injury to self or others.
f) Death of self or others.
g) Damage to the image and reputation of the entire homebuilding community.
Since I have a stake in e, f, and g, above I am making the educational
effort through these postings to help him make a better choice.
OC -- The best investment we will ever make is in gathering knowledge.
________________________________
Time: 10:53:58 AM PST US
From: Ernest Christley <echristley@nc.rr.com>
Subject: Re: AeroElectric-List: ABEA and TSO's
bakerocb@cox.net wrote:
> I understand that the AIM is not regulatory in nature, but I believe
> that an ABEA pilot having flown a GPS approach under IFR, and being
> called to account by the FAA or the NTSB for some sort of deviation or
> improper performance on his part would have a very difficult time
> convincing the authorities that his non TSO'd GPS equipment should be
> entirely acceptable to them.
Could you please stand back while I prepare to insert my foot in my
mouth, but...
That, to me, is a convoluted way of thinking. "There's no law against
it, but we don't like what you did." Is that any way to run a
country!? The AIM is not regulatory in nature. OK, then when
consideration of fines begin, it is immaterial. That just quacks to
much like "ex post facto" law to not be "ex post facto" law. If the
non-TSOed unit operated as advertised for several years, but then went
flaky enough to cause and incident, it would be no different than a
TSOed unit going tits-up. How an inspector 'feels' about it is smoke in
the wind.
> So the prudent ABEA builder / pilot does his homework and equips his
> aircraft so that it will perform in a manner that will not endanger
> him or others. If TSO'd equipment is the best way to accomplish that
> goal then his choice should be clear to him.
If non-TSOed equipment performs just as well at half the price, only
lacking the reams of paperwork required for the bureaucratic blessing,
why wouldn't the choice be equally clear? The builder has done the
pre-requisite homework, after all?
Ernest Christley
Message 4
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| Subject: | Re: ABEA and TSO's |
My 2 cents ( well maybe less) in support of Bob's arguments.
Liability culpability is generally based on the principle that a person may
be held liable if he/she does not do what a reasonable and PRUDENT person
would do in similar circumstances.
Ernest, based on your arguments, you are a reasonable person. Bob's
arguments are directed toward the PRUDENT part of the equation. If one
follows your position, you could, and would likely (with a respectable
offensive attorney), be found to be imprudent is you did not do the best
that you could to prevent/mitigate the incident for which you are being
tried. The result is that you would be guilty regardless of your "reason".
FWIW,
Doug Windhorn
----- Original Message -----
From: <bakerocb@cox.net>
<echristley@nc.rr.com>
Sent: Tuesday, 09 January, 2007 11:40
Subject: Avionics-List: ABEA and TSO's
>
> 1/9/2007
>
> Hello Ernest, Thanks for your input.
>
> 1) You wrote: "That, to me, is a convoluted way of thinking. "There's no
> law against
> it, but we don't like what you did." Is that any way to run a country!?
> The AIM is not regulatory in nature. OK, then when consideration of fines
> begin, it is immaterial."
>
> This may not be the best way to run a country, but it is the system we
> have come up with over the years and I don't expect it to change real
> soon.
>
> We have formal laws passed by congress (Title 14), we have regulations
> written by bureaucrats to implement those laws (FAR's), and we have non
> regulatory documents (Advisory Circulars, AIM, FAA Orders, etc.) to help
> interpret and implement those regulations. Then we have those same
> bureacrats (ninety percent of whom seem to be non-pilot lawyers)
> interpreting and enforcing those regulations.
>
> And I can assure you that if you are standing in front of an NTSB judge
> charged with violation of FAR 91 Careless and Reckless Operation because
> you violated a provision of the AIM that a potential fine and certificate
> action is not immaterial.
>
> 2) You wrote: "If the non-TSOed unit operated as advertised for several
> years, but then went
> flaky enough to cause and incident, it would be no different than a TSOed
> unit going tits-up. How an inspector 'feels' about it is smoke in the
> wind."
>
> The above is not an accurate description of the issue. The issue was a
> pilot knowingly using a non TSO'd unit to perform an IFR maneuver that the
> AIM said required a TSO'd unit (or equivalent) and a deviation or
> violation occurred. I wrote that the pilot could be subject to punishment
> for such a violation of the AIM. This is true.
>
> 3) You wrote: "If non-TSOed equipment performs just as well at half the
> price, only
> lacking the reams of paperwork required for the bureaucratic blessing, why
> wouldn't the choice be equally clear? The builder has done the
> pre-requisite homework, after all?"
>
> If the builder knowingly installs and uses non TSO'd (or equivalent)
> equipment to perform an IFR operation that the FAA intends should only be
> performed by TSO'd (or equivalent) equipment that builder is taking a
> risk. His risk could result in:
>
> a) No harm.
>
> b) Embarrassment.
>
> c) A fine.
>
> d) Loss of certificate
>
> e) Injury to self or others.
>
> f) Death of self or others.
>
> g) Damage to the image and reputation of the entire homebuilding
> community.
>
> Since I have a stake in e, f, and g, above I am making the educational
> effort through these postings to help him make a better choice.
>
> OC -- The best investment we will ever make is in gathering knowledge.
>
> ________________________________
>
> Time: 10:53:58 AM PST US
> From: Ernest Christley <echristley@nc.rr.com>
> Subject: Re: AeroElectric-List: ABEA and TSO's
>
> bakerocb@cox.net wrote:
>
>> I understand that the AIM is not regulatory in nature, but I believe
>> that an ABEA pilot having flown a GPS approach under IFR, and being
>> called to account by the FAA or the NTSB for some sort of deviation or
>> improper performance on his part would have a very difficult time
>> convincing the authorities that his non TSO'd GPS equipment should be
>> entirely acceptable to them.
>
> Could you please stand back while I prepare to insert my foot in my
> mouth, but...
>
> That, to me, is a convoluted way of thinking. "There's no law against
> it, but we don't like what you did." Is that any way to run a
> country!? The AIM is not regulatory in nature. OK, then when
> consideration of fines begin, it is immaterial. That just quacks to
> much like "ex post facto" law to not be "ex post facto" law. If the
> non-TSOed unit operated as advertised for several years, but then went
> flaky enough to cause and incident, it would be no different than a
> TSOed unit going tits-up. How an inspector 'feels' about it is smoke in
> the wind.
>
>> So the prudent ABEA builder / pilot does his homework and equips his
>> aircraft so that it will perform in a manner that will not endanger
>> him or others. If TSO'd equipment is the best way to accomplish that
>> goal then his choice should be clear to him.
>
> If non-TSOed equipment performs just as well at half the price, only
> lacking the reams of paperwork required for the bureaucratic blessing,
> why wouldn't the choice be equally clear? The builder has done the
> pre-requisite homework, after all?
>
> Ernest Christley
>
>
>
Message 5
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1/9/2007
Hello Bret:
1) You wrote: "As you can see, the FAA has left a wide loophole with the
phrase "or equivalent"."
The FAA has learned from experience that locking technical requirements in
bureaucratic documents in concrete can come back to bite them when
technology comes up with a better mouse trap that was not envisioned in the
document. So now-a-days they caveat their TSO's with a statement to the
effect that "if you can do it just as good, but maybe a little differently
we are willing to listen to your proposal."
The process for a request to deviate is described in FAR 21.609 and the
loophole is not that wide. You might find that entire FAR 21 Subpart O
interesting reading. You can see that obtaining TSO approval and
manufacturing in accordance with that approval can be burdensome.**
2) You wrote: "It appears that, from my understanding, a GPS used for IFR
navigation must meet the minimum standard of RTCA/DO-208 in order to meet
the standard of TSO-C129 in order to be approved for IFR navigation."
I agree. Also realize that there are other documents referenced in TSO-C129a
that may contain standards that the unit may have to meet. And the FAA may
chose to not incorporate all provisions of referenced documents into the
TSO. Some TSO's are absolutely infuriating -- they say nothing of substance
technically themselves, but instead reference several documents (such as SAE
documents) that cost a bunch of money for just three or four pages.
3) You wrote: "Problem is, I don't see where the FAA requires the GPS to be
"certified".
I agree. The words theFAA uses are "authorization (to perfom IFR operations)
requires equipment approved IAW TSO -C129" (version C129a is the current
version). Lawyers may not agree with me, but I bet the Garmin marketing
people looked at the FAA terminology of "authorization" and "approved" and
said "certified sounds better to us".
4) You wrote: "I may be confused here but it seems that when Garmin states
their GNS430 is "IFR Approach Certified", they are only stating that this
receiver meets the requirements of TSO-C129."
I agree -- and also meeting all the pertinent references to TSO-C129a and
permitting the FAA oversight of Garmin's production of the GNS 430. (See FAR
21.615).
In addition now Garmin is stating that the GNS 430W meets all the
requirements of TSO 146a.
OC -- The best investment we will ever make is in gathering knowledge.
**PS: I worked with Lance Turk, founder of Vision Microsystems, on a special
size oil temperature probe for my TCM engine. He would not make the probe
for me because it would be non TSO'd and he did not want to contaminate his
FAA TSO approved production line. I wound up buying an empty brass
temperature probe body from Westach and sending it to Lance so that he could
have one of his technicians epoxy one of the Vision Microsystems special oil
temperature probe sensors into that brass body's cavity. Works like a charm.
----- Original Message -----
From: "Bret Smith" <smithhb@tds.net>
Sent: Tuesday, January 09, 2007 3:19 PM
Subject: Re: GRT GPS TSO
OC,
This is truly fascinating.
You said >
4) If you had only a non TSO'd GPS aboard and performed a specific operation
that the AIM required a TSO approved GPS for then you would not be in
compliance with 1E and may be subject to a charge of careless or reckless T
operation (see FAR 91.13).
A brief perusal of the AIM revealed: (italics mine)
AIM 1-1-19
d. General Requirements
1. Authorization to conduct any GPS operation under IFR requires that:
(a) GPS navigation equipment used must be approved in accordance
with the requirements specified in Technical Standard Order (TSO) TSO-C129,
or equivalent, and the installation must be done in accordance with Advisory
Circular AC 20-138, Airworthiness Approval of Global Positioning System
(GPS) Navigation Equipment for Use as a VFR and IFR Supplemental Navigation
System, or Advisory Circular AC 20-130A, Airworthiness Approval of
Navigation or Flight Management Systems Integrating Multiple Navigation
Sensors, or equivalent. Equipment approved in accordance with TSO-C115a does
not meet the requirements of TSO-C129.
The words "must be approved..." pretty much settles the issue with me. Then
they continue on with the phrase "or equivalent". What would be equivalent
to TSO-C129? So off I go to read TSO-C129....
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/e560cd9c6acf8ba186256dc700717e0f/$FILE/C129a.pdf
I now know the requirements of any GPS to meet the TSO...
"Airborne supplemental area navigation equipment using GPS that are
to be so identified and that are manufactured on or after the date of this
TSO must meet the minimum performance standard of Section 2, RTCA,
Inc. Document No. RTCA/DO-208, "Minimum Operational Performance Standards
for Airborne Supplemental Navigation Equipment Using Global Positioning
System (GPS)," dated July 1991."
See the RTCA/DO-208 document here...
http://www.navcen.uscg.gov/cgsic/meetings/summaryrpts/31stmeeting/chesto/chesto.pdf
As you can see, the FAA has left a wide loophole with the phrase "or
equivalent". It appears that, from my understanding, a GPS used for IFR
navigation must meet the minimum standard of RTCA/DO-208 in order to meet
the standard of TSO-C129 in order to be approved for IFR navigation.
Problem is, I don't see where the FAA requires the GPS to be "certified". I
may be confused here but it seems that when Garmin states their GNS430 is
"IFR Approach Certified", they are only stating that this receiver meets the
requirements of TSO-C129.
Your thoughts are appreciated.
Bret
Message 6
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Folks,
The difference between the performance of TSO'd equipment and
apparently similar performance non-TSO'd equipment is not trivial.
There are very good reasons for requiring RAIM in C-129a units, for
most of the non-TSO units, there is no or inadequate internal
monitoring of the position solution and navigation output, as the
accident record shows, that can be seriously fatal.
Please, please, please, everybody, don't go flying IFR with non-TSO
GPS equipment, the database of demonstrated problems in the field is
hair-raising.
Just for starters, the integrity of the basic software (not the
navigation database) is unknown.
A hunt around the Australian CASA web site will find some
interesting facts about incidents and accidents, world wide, using
the wrong GPS in the wrong place, or drop Ian Mallet, head of the
GNSS Office at CASA an email, I am certain he will provide you with
some rather interesting references.
Cheers,
Bill Hamilton
At 09:10 AM 10/01/2007, you wrote:
>
>1/9/2007
>
>Hello Bret:
>
>1) You wrote: "As you can see, the FAA has left a wide loophole with
>the phrase "or equivalent"."
>
>The FAA has learned from experience that locking technical
>requirements in bureaucratic documents in concrete can come back to
>bite them when technology comes up with a better mouse trap that was
>not envisioned in the document. So now-a-days they caveat their
>TSO's with a statement to the effect that "if you can do it just as
>good, but maybe a little differently we are willing to listen to
>your proposal."
>
>The process for a request to deviate is described in FAR 21.609 and
>the loophole is not that wide. You might find that entire FAR 21
>Subpart O interesting reading. You can see that obtaining TSO
>approval and manufacturing in accordance with that approval can be
>burdensome.**
>
>2) You wrote: "It appears that, from my understanding, a GPS used
>for IFR navigation must meet the minimum standard of RTCA/DO-208 in
>order to meet the standard of TSO-C129 in order to be approved for
>IFR navigation."
>
>I agree. Also realize that there are other documents referenced in
>TSO-C129a that may contain standards that the unit may have to meet.
>And the FAA may chose to not incorporate all provisions of
>referenced documents into the TSO. Some TSO's are absolutely
>infuriating -- they say nothing of substance technically themselves,
>but instead reference several documents (such as SAE documents) that
>cost a bunch of money for just three or four pages.
>
>3) You wrote: "Problem is, I don't see where the FAA requires the
>GPS to be "certified".
>
>I agree. The words theFAA uses are "authorization (to perfom IFR
>operations) requires equipment approved IAW TSO -C129" (version
>C129a is the current version). Lawyers may not agree with me, but I
>bet the Garmin marketing people looked at the FAA terminology of
>"authorization" and "approved" and said "certified sounds better to us".
>
>4) You wrote: "I may be confused here but it seems that when Garmin
>states their GNS430 is "IFR Approach Certified", they are only
>stating that this receiver meets the requirements of TSO-C129."
>
>I agree -- and also meeting all the pertinent references to
>TSO-C129a and permitting the FAA oversight of Garmin's production of
>the GNS 430. (See FAR 21.615).
>
>In addition now Garmin is stating that the GNS 430W meets all the
>requirements of TSO 146a.
>
>OC -- The best investment we will ever make is in gathering knowledge.
>
>**PS: I worked with Lance Turk, founder of Vision Microsystems, on a
>special size oil temperature probe for my TCM engine. He would not
>make the probe for me because it would be non TSO'd and he did not
>want to contaminate his FAA TSO approved production line. I wound up
>buying an empty brass temperature probe body from Westach and
>sending it to Lance so that he could have one of his technicians
>epoxy one of the Vision Microsystems special oil temperature probe
>sensors into that brass body's cavity. Works like a charm.
>
>----- Original Message ----- From: "Bret Smith" <smithhb@tds.net>
>To: <bakerocb@cox.net>
>Sent: Tuesday, January 09, 2007 3:19 PM
>Subject: Re: GRT GPS TSO
>
>
>OC,
>
>This is truly fascinating.
>
>You said >
>4) If you had only a non TSO'd GPS aboard and performed a specific operation
>that the AIM required a TSO approved GPS for then you would not be in
>compliance with 1E and may be subject to a charge of careless or reckless T
>operation (see FAR 91.13).
>
>A brief perusal of the AIM revealed: (italics mine)
>
>AIM 1-1-19
>d. General Requirements
>
>1. Authorization to conduct any GPS operation under IFR requires that:
>
> (a) GPS navigation equipment used must be approved in
> accordance with the requirements specified in Technical Standard
> Order (TSO) TSO-C129, or equivalent, and the installation must be
> done in accordance with Advisory Circular AC 20-138, Airworthiness
> Approval of Global Positioning System (GPS) Navigation Equipment
> for Use as a VFR and IFR Supplemental Navigation System, or
> Advisory Circular AC 20-130A, Airworthiness Approval of Navigation
> or Flight Management Systems Integrating Multiple Navigation
> Sensors, or equivalent. Equipment approved in accordance with
> TSO-C115a does not meet the requirements of TSO-C129.
>
>The words "must be approved..." pretty much settles the issue with
>me. Then they continue on with the phrase "or equivalent". What
>would be equivalent to TSO-C129? So off I go to read TSO-C129....
>
>http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/e560cd9c6acf8ba186256dc700717e0f/$FILE/C129a.pdf
>
>I now know the requirements of any GPS to meet the TSO...
>
> "Airborne supplemental area navigation equipment using GPS
> that are to be so identified and that are manufactured on or after
> the date of this TSO must meet the minimum performance standard
> of Section 2, RTCA, Inc. Document No. RTCA/DO-208, "Minimum
> Operational Performance Standards for Airborne Supplemental
> Navigation Equipment Using Global Positioning System (GPS)," dated July 1991."
>
>See the RTCA/DO-208 document here...
>http://www.navcen.uscg.gov/cgsic/meetings/summaryrpts/31stmeeting/chesto/chesto.pdf
>
>As you can see, the FAA has left a wide loophole with the phrase "or
>equivalent". It appears that, from my understanding, a GPS used for
>IFR navigation must meet the minimum standard of RTCA/DO-208 in
>order to meet the standard of TSO-C129 in order to be approved for
>IFR navigation.
>
>Problem is, I don't see where the FAA requires the GPS to be
>"certified". I may be confused here but it seems that when Garmin
>states their GNS430 is "IFR Approach Certified", they are only
>stating that this receiver meets the requirements of TSO-C129.
>
>Your thoughts are appreciated.
>
>Bret
>
>
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