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PA28 "no IFR" limitation on GNS430, and backup NAV equipment requirement

Peter wrote:

Sure; I was trying to make the point that it was only the W box which needs an STC; a non-W can just go straight in. But that is current, not in 1999 or some such. Back then it was probably either STC or a TC approval, for any panel mounted GPS (the KMD150 was one curious exception).

Could you point to a reg for that? My understanding was the -W has got an STC, while non-W is still screwed, and cannot be used for IFR nav without an STC (major mod).

EGTR

arj1 wrote:

Could you point to a reg for that? My understanding was the -W has got an STC, while non-W is still screwed, and cannot be used for IFR nav without an STC (major mod).

This isn’t correct – see my previous post. The EASA Approval number for the Minor Change AFMS is EASA.A.A.02128 and Gama Aviation can supply copies of the complete data package (HL/MOD/1057) still even though they’re no longer an EASA Part 21J DOA.

Avionics geek.
Somewhere remote in Devon, UK.

cannot be used for IFR nav

That sort of phrase has been common from national CAAs in years past and is always BS, simply because there is no supporting reg on how one is supposed to navigate. The regs are always concerning equipment carriage not equipment usage. Equipment usage is the province of ops manuals i.e. AOC ops.

=

always

Administrator
Shoreham EGKA, United Kingdom

As mentioned, the Gama Minor Change does approve IFR. it was written prior to EASA creating CS-ACNS, hence the reference to CAA CAP773.
This is an extract from the AFMS:

Last Edited by wigglyamp at 24 Nov 09:21
Avionics geek.
Somewhere remote in Devon, UK.

Thanks for all the replies, including the most practical one of a firm tug .

Some additional information is that this is an Archer III (-181) built in the early 00’s, with two (non-W) GNS430s from factory.

@wigglylamp, thanks for the reference and info, will look into that some more.

United Kingdom

In the US, any TSO C129 GPS was never approved to satisfy 91.205(d)(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

From AC 20-138D:

a. TSO-C129 and TSO-C196 are positioning and navigation systems with equipment limitations for the aircraft to have other navigation equipment available appropriate to the operation and for alternate airport flight planning.

The TSO C129 GNS430 has a built in VOR Nav receiver which allows it to comply with 91.205(d), but the GPS navigation function by itself does not comply. It wasn’t until version 3.0 of the GNS430W main software and an updated antenna, that the GPS function was deemed acceptable to meet the requirements of 91.205(d)(2).

The original GNS430 did not have an STC and was installed with using a field approval as a follow on to a Garmin STC for a single aircraft type. When Garmin purchased UPS Apollo, they adopted the AML STC approach used by UPS Apollo for the GNS430W. This made installation a less time consuming enterprise as the field approval step was eliminated and the STC included a pre-approved AFMS for IFR operation. Prior to that point, every install needed to edit a sample AFMS and submit it separately with a 337 field approval to get IFR approval.

KUZA, United States

The TSO C129 GNS430 has a built in VOR Nav receiver which allows it to comply with 91.205(d), but the GPS navigation function by itself does not comply

That would suggest that, in the US, a GNS430 was OK for flying a VOR-based route (which is how traditional IFR worked in the US for many years) but was never (even today) OK for flying some long DCT.

If this is correct, it must have been totally disregarded by everybody.

The original GNS430 did not have an STC and was installed with using a field approval

Same in Europe until Garmin purchased the Universe (somehow got EASA to agree to AML STCs, despite EASA saying for years they would never do so), except that for “using a field approval” you substitute a Major Mod.

Administrator
Shoreham EGKA, United Kingdom

NCYankee wrote:

In the US, any TSO C129 GPS was never approved to satisfy 91.205(d)(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

What is the difference between suitable as primary navigation? suitable as alternate mean of navigation? and suitable as substitute mean of navigation?

I recall reading that between lines in ENR1.17 with distinction between 146 WAAS and 129 without WAAS (maybe it’s out of date)

https://www.faa.gov/air_traffic/publications/atpubs/aip_html/part2_enr_section_1.17.html

Last Edited by Ibra at 24 Nov 17:44
Paris/Essex, France/UK, United Kingdom

Peter wrote:

That would suggest that, in the US, a GNS430 was OK for flying a VOR-based route (which is how traditional IFR worked in the US for many years) but was never (even today) OK for flying some long DCT.

If this is correct, it must have been totally disregarded by everybody.

No, without a VOR on board, the GPS could not be the sole means of navigation available. So if the GNS420 (GPS/Com) or GNS400 (GPS only) was the only navigation system on board, the flight would not be legal. but once you have added a VOR, the flight is legal even though you don’t plan on using the VOR for the route. If GPS failed, you would then revert to direct to a VOR and then by airways based on VOR. So GPS can’t be used as the “SOLE” means of navigation available for the flight. With the GNS400W/420W software version 3.0+ and a compliant antenna, the aircraft was no longer required to have a VOR to meet the 91.205(d)(2) requirement. It was called Sole means of IFR navigation. So if all your VOR systems failed today, the KLN94 would not be legal for IFR flight in the US, but if you had a GPS 175 as your only navigation source, it would be legal.

KUZA, United States

OK; almost nobody used the 400 or the 420 over here.

The KLN94 would always be accompanied by a VHF COM/NAV radio.

Administrator
Shoreham EGKA, United Kingdom
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