bakerocb(at)cox.net
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 Posted: Wed Jan 11, 2006 3:11 pm Post subject: IFR GPS |
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1/11/2006
Hello Wayne, I'll give it a shot. (See Wayne's request copied below).
1) You wrote: "......skip..... the unit must meet the the guidelines per
TSO-C129, however changing they may be."
The current version of TSO-C129 is TSO C129a dated 2/20/1996. It has been
almost 10 years since there have been any changes to that TSO. So any
argument that one tries to make that compliance is difficult because of
changes to the TSO is not very valid.
I also think that it is rather useless for individuals to talk about
compliance with a TSO or equivalent. TSO's are basically shell documents and
the real guts of a TSO lies in all the technical references that a TSO
usually contains. (TSO-C129a is much better than most in that regard -- it
actually has some specific content.) Even if an individual spent all the
money and time to assemble all the references it would then take tremendous
technical, financial, and material resources to attempt to comply with them
and to prove to the FAA that you were complying with them.
The fact of the matter is that individuals either comply with TSO-C129a by
buying a box so labeled or they are not in compliance. It is much more
relevant to be discussing an individual's compliance with the FAR's and the
AIM.
2) You wrote: " We have a fellow who thinks he can use the GPS in a Blue
Mountain EFIS 1 for primary nav in the enroute phase."
3) The Blue Mountain web site FAQ list contains this: "Question: Is EFIS/One
certified for GPS approaches?
Answer: On the advice of our most trusted avionics dealer and partner, we
have decided not to pursue it. For what it will cost to do TSO C129A testing
and certification, we'd have to raise the price of the EFIS by more than the
cost of a high-volume certified unit. We think it's a better deal to have a
reasonably priced glass cockpit, and the interconnect available for those
who want to fly GPS approaches. If you have a certified GPS, you can plug it
in to drive the flight director and autopilot in approach mode."
So that clearly establishes that the Blue Mountain EFIS does not meet the
criteria of TSO-C129a.
4) Your subject line says GPS IFR flight.
AIM paragraph 1-1-19 d. 1. says "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,....skip...."
Note 4 to Table 1-1-6 in the AIM says "VFR and hand-held GPS systems are not
authorized for IFR navigation, instrument approaches, or as a primary
instrument flight reference. During IFR operations they may be considered
only an aid to situational awareness."
AIM paragraph 1-1-19 d. 1. (b) says "Aircraft using GPS navigation equipment
under IFR must be equipped with an approved and operational alternate means
of navigation appropriate to the flight."
CFR 14 Sec. 91.205 (d) (2) requires "Two-way radio communications system and
navigational equipment appropriate to the ground facilities to be used."
Seems pretty clear to me that the GPS capability in a Blue Mountain EFIS
cannot be used as a primary means of IFR enroute navigation. If this fellow
has a counter argument I'd like to read it along with the pertinent
references.
5) But there is nothing stopping the fellow from launching off on a VOR
filed IFR flight plan and then working the ATC system to allow him to go as
direct as they and his GPS will allow him to. The gotcha is that he better
be ready to ready at any time to navigate by VOR.
OC
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