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GPS question - replacing a Trimble 2000

boscomantico wrote:

What is “primary navigation” in VFR after all?

Well, if you navigate visually, then official paper chart can be used as primary means. And nothing is stopping you from using certified radio navigation equipment (that’s why it’s taught). Looking out is quite poor means of navigation when flying above a solid enough undercast (which is legal a lot of places). It gets more interesting when you want to use something not certified/ approved as primary.

Please proceed…

Mainz (EDFZ) & Egelsbach (EDFE), Germany

I would like to see a reference for “primary navigation”.

That term has consumed more GB on forums than most things, yet – for Europe – nobody as IIRC ever come up with a legal reference. IMHO it is meaningless.

In addition, there is a specific distinction between equipment to be carried (prescribed widely) and equipment to be used (prescribed almost never in private flying). Obviously you have to carry specific panel mounted (certified, etc) gear for certain operations / classes of airspace / etc) but nobody can prosecute you if you post openly that you navigate everywhere with an Ipad. Well, if you were doing something crazy they could get you under a general “dangerous flying” clause which exists in UK law and probably everywhere else. But the vast majority of light GA navigates with Ipads nowadays…

Maybe there is something in the FAR-AIM (the USA) but that isn’t law either. It’s a book written largely 15+ years ago by a John Lynch, and others, and interprets US law. A bit like the LASORS book interpreted UK law, adding bits which the CAA had discretion to invent internally. The FAR-AIM has loads of ambiguous bits but most people are happy with that.

Obviously AOC ops are a totally different topic, and there specific procedures are prescribed and have to be followed.

Administrator
Shoreham EGKA, United Kingdom

NCYankee wrote:

Some of these statements only apply to certificated operators (airline, charter, etc.) or to large turbine aircraft. EFB can’t be used by these operators to depict aircraft own ship because airline pilots are too untrustworthy and might navigate by using the EFB if it showed them where they are. Interestingly enough, it can be used on the ground as long as the GS is <80 Kts and in the air, a feature can be provided to center the map on the current position, but don’t dare let the pilot know or he might crash. :)

EASA seems to think the same for AOC operators. Not applicable to private operators either.

NCYankee wrote:

With the advent of Aspen’s connected panel and later the Garmin Flight Stream, flightplan routes may be transferred to/from an EFB and my installation provides panel mount GPS position, pressure altitude, traffic, and weather to my iPad from the certified equipment.

This is where the FAA is more liberal then EASA. These connections are not always allowed under EASA.

JP-Avionics
EHMZ

It would be really interesting to find out how exactly stuff like the “connected cockpit” could ever be certified. I mean the exact process; not PR stuff. That was not possible for decades.

The old Garmin / Jeppesen Flight Plan Migrator was a crappy solution, seemingly done to limit the data being transferred to a textual (XML, IIRC) representation of the route which could be parsed with code which could be “provably” robust and not open an exploit into the GPS box.

Before that, Chelton (IIRC) had a slicker FP transfer means, via an SD or CF card, but that company never marketed anything they had.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

It would be really interesting to find out how exactly stuff like the “connected cockpit” could ever be certified. I mean the exact process;

Just like anything else, proof that it is safe to use such a system and confirms to certifications specifications.

JP-Avionics
EHMZ

How come Honeywell could not do it (KLN94, etc) and Garmin could not do it (GNS, GTN, G500, G1000) until their hand was forced by e.g. Voiceflight’s reverse engineering of the crossfill bus.

Electronic FP loading has been the most blindingly obvious requirement for the 15 years I have been flying and probably before.

Administrator
Shoreham EGKA, United Kingdom

Agree, there is no definition of primary navigation as it is more a term of art, but 91.205 specifies that for IFR flight, navigation equipment suitable for the route to be flown. VFR has no required navigation equipment requirement. Equipment that is not installed in the aircraft is not considered as a part of the aircraft and therefore can never be suitable.

23.1307 states in part: “The equipment necessary for an airplane to operate at the maximum operating altitude and in the kinds of operations and meteorological conditions for which certification is requested and is approved in accordance with Sec. 23.1559 must be included in the type design.” IOW, the equipment installed in the aircraft that meets the IFR requirement must be part of the Type Certificate or an STC, or a field approval for a major modification.

KUZA, United States

Peter wrote:

Maybe there is something in the FAR-AIM (the USA) but that isn’t law either. It’s a book written largely 15+ years ago by a John Lynch, and others, and interprets US law. A bit like the LASORS book interpreted UK law, adding bits which the CAA had discretion to invent internally. The FAR-AIM has loads of ambiguous bits but most people are happy with that.

The FAR-AIM is two documents in one, the FAR is a reprint of certain regulation sections most often used by pilots. The AIM has been produced as long as I can remember and was always intended as guidance and never as regulatory. It has had many authors and rewrites as time has gone by. A few sections were direct responses to questions I raised. I recall John Lynch had a frequently asked question list that he made available, but later was taken down because he did not speak for the FAA in terms of interpreting the regulations. The FAA General Counsel reserves that authority unless a court orders otherwise.

KUZA, United States

Thanks for the clarification NCYankee.

FWIW the last known version of the FAA FAQ from John Lynch is here (and at other places).

Equipment that is not installed in the aircraft is not considered as a part of the aircraft and therefore can never be suitable.

That would imply that a tablet (etc) is somehow illegal to navigate with. I am sure that’s not the case (well, obviously it cannot be). I believe a lot of people have examined the US regs over the years and concluded everything is legal to use. What you have to carry is a different thing and is much clearer.

In private flight (Part 91) there is no automatic linkage between carriage and usage, AIUI, and this is also the case in Europe.

Administrator
Shoreham EGKA, United Kingdom
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