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91.205 (WAAS)

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dan.beadle(at)inclinesoft
Guest

Posted: Wed Jan 03, 2007 10:11 pm Post subject: 91.205 (WAAS)

The key is the 146 TSO.  Without that, GPS is just a backup system. VOR or

NDB must be primary.  (We all know, that we fly it the other way around).

In some cases, like flying direct, we can't even use VORs (too high, too

low, too far away).  But if we are at vectoring altitudes with radar

coverage, again we can use the non-146 GPS as Secondary (even tho VOR is out

of range.)  



With 146 TSO, it is a new ballgame - no underlying VOR required. 



--

sportav8r(at)gmail.com
Guest

Posted: Thu Jan 04, 2007 5:09 am Post subject: 91.205 (WAAS)

Question from a fledgeling IFR student (meaning I've begun reading for

the written, but have zero instructional time with a live mentor so

far):  The practical flight test standards call for 3 different types

of instrument approaches to be made, a requirement that I interpret to

mean an NDB would be required if there were not an approach-certified

GPS on board to substitute for it (localizer and ILS being the other

two types of approach I can think of).  Without getting sidetracked

into a discussion of how to avoid unpopular NDB navigation, can you

explain how one might satisfy the training and checkride requirements

in a WAAS-GPS-only equipped plane with no VHF nav?  You didn't say

this was the case, but the question has relevance to me as a

homebuilder still planning his IFR panel upgrade.



Thanks, gentlemen.



Bill B.



On 1/4/07, Dan Beadle <dan.beadle(at)inclinesoftworks.com> wrote:

[quote] 



 The key is the 146 TSO.  Without that, GPS is just a backup system. VOR or

 NDB must be primary.  (We all know, that we fly it the other way around).

 In some cases, like flying direct, we can't even use VORs (too high, too

 low, too far away).  But if we are at vectoring altitudes with radar

 coverage, again we can use the non-146 GPS as Secondary (even tho VOR is out

 of range.)



 With 146 TSO, it is a new ballgame - no underlying VOR required.



 --

sportav8r(at)gmail.com
Guest

Posted: Thu Jan 04, 2007 5:15 am Post subject: 91.205 (WAAS)

Corollary question to my own, below:  any thoughts on how one

practices partial panel training and checkride performance when all

the flight instruments exist only on a pair of redundant glass EFIS's?

 I'm a bit worried the examiner is going to balk at giving me a

checkride in my own expereimental if there is no way for him to

selectively fail just the airspeed or HSI or altimeter or whatever.

Any real-world failure of an AHRS would be detected by automated cross

check between the two AHRS units, and the A/P gyro info would tell me

which AHS was spewing bad data.  Such a scenario seems to throw a

monkey wrench into the archaic training and testing standards that

were written in the days of the six-pack of gyro and electric

instruments.  Anyone been there and done that with an examiner?



-Bill B.



On 1/4/07, Bill Boyd <sportav8r(at)gmail.com> wrote:

[quote] Question from a fledgeling IFR student (meaning I've begun reading for

 the written, but have zero instructional time with a live mentor so

 far):  The practical flight test standards call for 3 different types

 of instrument approaches to be made, a requirement that I interpret to

 mean an NDB would be required if there were not an approach-certified

 GPS on board to substitute for it (localizer and ILS being the other

 two types of approach I can think of).  Without getting sidetracked

 into a discussion of how to avoid unpopular NDB navigation, can you

 explain how one might satisfy the training and checkride requirements

 in a WAAS-GPS-only equipped plane with no VHF nav?  You didn't say

 this was the case, but the question has relevance to me as a

 homebuilder still planning his IFR panel upgrade.



 Thanks, gentlemen.



 Bill B.



 On 1/4/07, Dan Beadle <dan.beadle(at)inclinesoftworks.com> wrote:

 > 

 >

 > The key is the 146 TSO.  Without that, GPS is just a backup system. VOR or

 > NDB must be primary.  (We all know, that we fly it the other way around).

 > In some cases, like flying direct, we can't even use VORs (too high, too

 > low, too far away).  But if we are at vectoring altitudes with radar

 > coverage, again we can use the non-146 GPS as Secondary (even tho VOR is out

 > of range.)

 >

 > With 146 TSO, it is a new ballgame - no underlying VOR required.

 >

 > --

Bret Smith

Joined: 09 Jan 2006
Posts: 178
Location: Mineral Bluff, GA

Posted: Thu Jan 04, 2007 7:02 am Post subject: 91.205 (WAAS)

Bill,



When I took my IFR checkride, my plane (C172) was not equipped with an ADF, 

thus, no NDB approach.  I ended up shooting an ILS and LOC at Knoxville, TN 

and a GPS approach at Andrews-Murphy, NC.



As far as partial panel with glass EFIS, most examiners will use good-ol 

"sticky notes" to cover up relevant areas of the display.  I have the number 

of my examiner who would be glad to discuss any questions with you via 

phone.  Let me know if you want his number.



Bret

---

_________________
Bret Smith
RV-9A (Emp)

BobsV35B(at)aol.com
Guest

Posted: Thu Jan 04, 2007 7:49 am Post subject: 91.205 (WAAS)

Good Morning OC,   

 Great comments.

  

 May I use your message as a springboard to further discussion? 

  

 Somebody on this thread referred to the C129 approval as "GPS is  just a backup system". That imply's that you must have a VOR based plan in use  all the time you are navigating via GPS. 

  

 I have even read some comments that state you cannot fly a VOR defined  airway unless the VORs are in service. 

  

 That is NOT the intent of the approval. 

  

 The GPS under 129 is a Supplementary System, not a "back up" system.   

  

 You can shoot an NDB or a VOR approach using GPS as long as it has an  approved overlay procedure. The underlying VOR or NDB does not have to be in  service or monitored if it is in service. The same goes for flying an airway,  you can fly the airway using the GPS even if every VOR along the way is  inoperative. What you must have is a plan to be able to safely revert to a plan  of action that will allow you to safely navigate following the loss of the GPS.  

  

 The precise way you do that is not specified.

  

 If whatever you do ends up in an incident, you may have to explain your  reasoning at a hearing. Highly unlikely, but always a possibility for any flight  with any equipment!

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

Stearman  N3977A

Brookeridge Air Park LL22

Downers Grove, IL 60516

630  985-8503



  

 In a message dated 1/4/2007 8:20:21 A.M. Central Standard Time,  bakerocb(at)cox.net writes:

  	  Quote: 	
		  Hello    Wayne, Thanks for your quick response.



I wrote: " 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."



And you wrote: "I wish we could somehow train the DAR and ABEA    communities 

to accept this."



I don't agree with the concept of    required acceptance by a DAR or FAA 

inspector during an initial    airworthiness inspection of an ABEA's (Amateur 

Built Experimental    Aircraft's) avionics suite configuration and eventual use 

of that ABEA in    IFR flight .



The inspector is not in a position to pass judgement on    such future IFR 

employment of the aircraft or enforce equipment provisions    for that future 

employment. Instead the inspector places such judgement    and future 

responsibility for compliance with FAR's and the AIM equipment    requirements 

on the builder / pilot by the wording of that ABEA's    Operating Limitations. 

To whit: â€œAfter 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.â€



I suppose it is possible that an FAA ramp inspector after an IFR    flight, or 

an investigation after an incident, could conclude that an ABEA    equipped 

with only 146 TSO'd compliant WAAS equipment was in violation of    minimum IFR 

navigation equipment requirements, but that is not my    interpretation of the 

words available to me.



OC -- The best    investment we will ever make is in gathering  knowledge.



	


 



  

  [quote][b]

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jan 05, 2007 5:42 am Post subject: 91.205 (WAAS)

1/5/2007



Hello Marcel, Thank you for your input. I welcome information from across 

the ocean.



You wrote: "This combined with addition of WAAS may make the difference of 

being able to

certify for IFR operation in your experimental."



One of my major points is that there is no such thing as "certifying for IFR 

operation" in an ABEA (Amateur Built Experimental Aircraft) here in the US. 

The FAA has neither the capability or, under the present FAR's, the process 

to certify an ABEA for IFR operations.



Instead, for the equipment required for IFR operations, the builder / pilot 

is given the responsibility in the aircraft's Operating Limitations to 

comply with FAR 91.205, part of which requires: "Two way radio 

communications system and navigational equipment appropriate to the ground 

facilities to be used".



OC -- The best investment we will ever make is in gathering knowledge.



Time: 01:52:42 AM PST US

From: "RAS" <deruiteraircraftservices(at)btinternet.com>

Subject: Re: Re: 91.205 (WAAS)

Hi,



apologies for butting in on this. We have a RV10 with full Garmin stack and

have had quite some difficulty getting pin outs and ended up sending the

units to an avionics shop to get wired. (we purchased without looms)

I have since spoken to the main Garmin agent in the UK and he explained that

due to complexity of the avionics Garmin does not encourage(read does not

make available pinout)homebuilders to do their own wiring.



This can well be where the snag is in this story. You buy Garmin with a

manufactored loom which is tested for proper function and there's a degree

of assured quality.

This combined with addition of WAAS may make the difference of being able to

certify for IFR operation in your experimental.

It may also be a good idea to print a copy of 91.205 to hand over to your

DAR if he doesn't sign willingly! 



Marcel

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jan 05, 2007 8:12 am Post subject: 91.205 (WAAS)

1/5/2007



Hello Bill, Welcome to the world of IFR flight and thanks for your 

questions.



You wrote: "....skip....can you explain how one might satisfy the training 

and checkride requirements in a WAAS-GPS-only equipped plane with no VHF 

nav?"



No, I can't. But let's examine the reality of a WAAS-GPS-only equipped 

plane. I can't speak for the high end integrated systems (Chelton, Avidyne, 

etc.), but the Garmin 400 / 500 series GPS units that can be upgraded to a 

430W or 530W configuration already contain VHF nav capability. I presume the 

newly built 430W and 530W boxes will also contain VHF nav capability. So one 

will continue to have VHF nav capability even after a WAAS upgrade or new 

purchase with these kinds of boxes.



Maybe an issue is whether or not one should plan on / need a separate VHF 

nav box such as an SL-30 for back up purposes.**



A) So with an approach qualified GPS (non WAAS capable) and VHF nav one can 

have four different instrument approaches to demonstrate to an examiner: 1) 

VOR, 2) Localizer, 3) ILS, 4) GPS.



B) With an approach qualified GPS (with WAAS capability) and VHF nav one can 

have five different instrument approaches to demonstrate to an examiner: 1) 

VOR, 2) Localizer, 3) ILS, 4) GPS, 5) an approach that requires WAAS to 

achieve the published minimums.



C) With no approach qualified GPS and only VHF nav one can have three 

different instrument approaches to demonstrate to an examiner: 1) VOR, 2) 

Localizer, 3) ILS.



And the question of ADF capability in your aircraft doesn't need to raise 

its ugly head unless you choose to use some GPS capability to substitute for 

a NDB where permitted.



You might want to discuss the above positions with your examiner prior to 

showing up for the practical test to determine if he agrees.



OC -- The best investment we will ever make is in gathering knowledge.



**PS: I use my GNS 430 and SL-30 together whenever possible. If one intends 

to fly IFR to the extent that an approach capable GPS is needed then I think 

the investment in a separate VHF nav box is well justified.

Time: 05:09:11 AM PST US

From: "Bill Boyd" <sportav8r(at)gmail.com>

Subject: Re: AeroElectric-List: Re: 91.205 (WAAS)

Question from a fledgeling IFR student (meaning I've begun reading for

the written, but have zero instructional time with a live mentor so

far):  The practical flight test standards call for 3 different types

of instrument approaches to be made, a requirement that I interpret to

mean an NDB would be required if there were not an approach-certified

GPS on board to substitute for it (localizer and ILS being the other

two types of approach I can think of).  Without getting sidetracked

into a discussion of how to avoid unpopular NDB navigation, can you

explain how one might satisfy the training and checkride requirements

in a WAAS-GPS-only equipped plane with no VHF nav?  You didn't say

this was the case, but the question has relevance to me as a

homebuilder still planning his IFR panel upgrade.



Thanks, gentlemen.



Bill B.

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jan 05, 2007 2:02 pm Post subject: 91.205 (WAAS)

1/5/2007



Hello Bill,



1) You wrote: " Sorry to cloud any points in the thread."



Not a problem at all -- you gave us an opportunity to broaden the picture a 

bit.



2) You wrote: "....skip.....the question more heavily on my mind: about

the adequacy of the WAAS / internal GPS being brought out by Grand

Rapids Tech for the EFIS system I'm planning to install"



Now this raises a very interesting issue. Is GRT going to TSO this 

equipment? They haven't gone that route in the past.



Note that paragraph 1-1-20 c of the aim requires that WAAS avionics meet 

either TSO C145 or 146A.



Your SL-30 would make it legal to fly IFR, but if your GRT WAAS / internal 

GPS in your EFIS is not TSO'd it is not clear to me what additional legal 

value it would have when operating IFR. Like any other reasonably capable 

GPS unit it could provide very beneficial situational awareness support.



OC -- The best investment we will ever make is in gathering knowledge.



---

sportav8r(at)gmail.com
Guest

Posted: Fri Jan 05, 2007 3:52 pm Post subject: 91.205 (WAAS)

My understanding from talking to them is that it would be fully

approach-legal in its final form.  How they plan to accomplish that

"legislatively" I am less clear on, but they convinced me that, for my

purposes (IFR with gps approach capability), their unit plus an SL30

would completely do away with the need for a 430 or 530 in my panel.

Maybe someone (else) from the GRT_EFIS group will chime in here.



-Bill



On 1/5/07, bakerocb(at)cox.net <bakerocb(at)cox.net> wrote:

[quote] 



 1/5/2007



 Hello Bill,



 1) You wrote: " Sorry to cloud any points in the thread."



 Not a problem at all -- you gave us an opportunity to broaden the picture a

 bit.



 2) You wrote: "....skip.....the question more heavily on my mind: about

 the adequacy of the WAAS / internal GPS being brought out by Grand

 Rapids Tech for the EFIS system I'm planning to install"



 Now this raises a very interesting issue. Is GRT going to TSO this

 equipment? They haven't gone that route in the past.



 Note that paragraph 1-1-20 c of the aim requires that WAAS avionics meet

 either TSO C145 or 146A.



 Your SL-30 would make it legal to fly IFR, but if your GRT WAAS / internal

 GPS in your EFIS is not TSO'd it is not clear to me what additional legal

 value it would have when operating IFR. Like any other reasonably capable

 GPS unit it could provide very beneficial situational awareness support.



 OC -- The best investment we will ever make is in gathering knowledge.



 ---

Bret Smith

Joined: 09 Jan 2006
Posts: 178
Location: Mineral Bluff, GA

Posted: Fri Jan 05, 2007 7:07 pm Post subject: 91.205 (WAAS)

See http://www.grtavionics.com/documents/Horizon%20System%20Flyer.pdf



"The addition of the internal GPS receiver eliminates the need for an

external

GPS, or may be used as a backup to your primary GPS. Available in two

versions. The standard WAAS GPS module is perfect for VFR use, or as backup

to an external GPS. The new RAIM-equipped version provides integrity

monitoring and 5 updates per second to meet the requirements of IFR GPS

TSO C129 and C146."



Standard WAAS GPS Receiver with antenna $450

RAIM-Equipped WAAS GPS Receiver with antenna $750

 

Bret Smith

RV-9A (91314)

Mineral Bluff, GA

www.FlightInnovations.com



--

_________________
Bret Smith
RV-9A (Emp)

khorton01(at)rogers.com
Guest

Posted: Sat Jan 06, 2007 4:24 am Post subject: 91.205 (WAAS)

I'd ask to see a copy of the letters from the FAA that confirm the  

TSOs have been issued.



Kevin Horton

On 5 Jan 2007, at 22:05, Bret Smith wrote:



[quote] 

 <smithhb(at)tds.net>



 See http://www.grtavionics.com/documents/Horizon%20System%20Flyer.pdf



 "The addition of the internal GPS receiver eliminates the need for an

 external

 GPS, or may be used as a backup to your primary GPS. Available in two

 versions. The standard WAAS GPS module is perfect for VFR use, or  

 as backup

 to an external GPS. The new RAIM-equipped version provides integrity

 monitoring and 5 updates per second to meet the requirements of IFR  

 GPS

 TSO C129 and C146."



 Standard WAAS GPS Receiver with antenna $450

 RAIM-Equipped WAAS GPS Receiver with antenna $750



 Bret Smith

 RV-9A (91314)

 Mineral Bluff, GA

 www.FlightInnovations.com



 --

BobsV35B(at)aol.com
Guest

Posted: Sat Jan 06, 2007 6:53 am Post subject: 91.205 (WAAS)

Good Morning Kevin,   

 I am definitely stepping out from my area of expertise here, but is a TSO  required for operations of a home built aircraft?

  

 It isn't even required for all operations of certificated aircraft. 

  

 The determination of the equipment that is required for IFR flight appears  to be left up to the operator. As long as the operator determines that the  equipment meets the standards required for IFR flight, the stuff should be  acceptable.

  

 What do you feel is required?

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

Stearman  N3977A

Brookeridge Air Park LL22

Downers Grove, IL 60516

630  985-8503



  

 In a message dated 1/6/2007 6:26:49 A.M. Central Standard Time,  khorton01(at)rogers.com writes:

  	  Quote: 	
		  I'd ask    to see a copy of the letters from the FAA that confirm the  

TSOs have    been issued.



Kevin Horton

	


 



  [quote][b]

flyboy.bob(at)gmail.com
Guest

Posted: Sat Jan 06, 2007 7:17 am Post subject: 91.205 (WAAS)

Bob,



You may be right?  But most, if not all, of us lack the test equipment

to 'prove' that a given piece of equipment "meets the standards

required for IFR flight"?!



If the manufacture hasn't gone to the trouble and expense to show

their equipment meets 'standards' how can I?  . . .  Buying TSO'd

reduces that concern if you have it in the first place.



It's been awhile but I'm pretty sure the 'equipment requirements' for

IFR Flight indicate that certain equipment meet TSO standards?



My $0.02 worth!



Bob in SE Iowa

RV-8 builder - finishing slowly



On 1/6/07, BobsV35B(at)aol.com <BobsV35B(at)aol.com> wrote:

 	  Quote: 	
		  



 Good Morning Kevin,



 I am definitely stepping out from my area of expertise here, but is a TSO

 required for operations of a home built aircraft?



 It isn't even required for all operations of certificated aircraft.



 The determination of the equipment that is required for IFR flight appears

 to be left up to the operator. As long as the operator determines that the

 equipment meets the standards required for IFR flight, the stuff should be

 acceptable.



 What do you feel is required?



 Happy Skies,



 Old Bob

 AKA

 Bob Siegfried

 Ancient Aviator

 Stearman N3977A

 Brookeridge Air Park LL22

 Downers Grove, IL 60516

 630 985-8503



 In a message dated 1/6/2007 6:26:49 A.M. Central Standard Time,

 khorton01(at)rogers.com writes:

 I'd ask to see a copy of the letters from the FAA that confirm the

 TSOs have been issued.



 Kevin Horton




	


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BobsV35B(at)aol.com
Guest

Posted: Sat Jan 06, 2007 7:55 am Post subject: 91.205 (WAAS)

Good Morning Bob,   

 Now I am getting way, way, out of my area. 

  

 However! 

  

 Meeting the TSO standards and being certified by the FAA as meeting those  standards are two different things.

  

 Fortunately for us, the FAA rules and regulations are permissive, not  restrictive. If something is not specifically prohibited, we can do it. If what  we do causes a problem that the FAA thinks shouldn't have occurred, they can go  after us via the careless and reckless provisions of the regulations.

  

 For most Part 135 operations, the radio gear must be FAA certified as  meeting the TSO standards, for the rest of us, all we need to know is that the  manufacturer feels they meet the standards. As I see it, we are not required to  do the testing ourselves. I am not at all up to date on such things, but I do  recall flying many hundreds, if not thousands, of IFR hours using equipment that  was not certified by the FAA as meeting the applicable TSO's but that did work  just fine for our Part 91 functions. 

  

 Once again, my disclaimer, I am no longer active in that area and I could  very likely be way off base. Please let me know if that is true!

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

Stearman  N3977A

Brookeridge Air Park LL22

Downers Grove, IL 60516

630  985-8503



  

 In a message dated 1/6/2007 9:19:26 A.M. Central Standard Time,  flyboy.bob(at)gmail.com writes:

  	  Quote: 	
		  Bob,



You may be right?  But most, if not all, of us lack    the test equipment

to 'prove' that a given piece of equipment "meets the    standards

required for IFR flight"?!



If the manufacture hasn't gone    to the trouble and expense to show

their equipment meets 'standards' how    can I?  . . .  Buying TSO'd

reduces that concern if you have it    in the first place.



It's been awhile but I'm pretty sure the 'equipment    requirements' for

IFR Flight indicate that certain equipment meet TSO    standards?



My $0.02 worth!



Bob in SE  Iowa

	


 



  [quote][b]

khorton01(at)rogers.com
Guest

Posted: Sat Jan 06, 2007 10:28 am Post subject: 91.205 (WAAS)

Bob,



I believe that the FAA's intent is that GPS equipment used for IFR  

must be TSO approved to either TSO C129, C129A, C145A or C146A.   

AC90-94 Guidelines for using Global Positioning System Equipment for  

IFR En Route and Terminal Operations and for Nonprecision Instrument  

Approaches in the U.S. National Airspace System says that GPS  

equipment for use in the US National Airspace System should in  

installed in accordance with AC20-138, which requires TSO'd GPS  

receivers.  I'll be the first to admit that an AC is not a  

regulation, but if you want to propose an alternate means of  

compliance you need to get the FAA to agree to it.  I am not a  

lawyer, so I won't attempt to define the clear regulatory trail that  

would require TSO's GPS receivers.



I wish the regs were clearer in this area.  You shouldn't need to  

hire a lawyer to figure out what the regulatory requirements are.



The situation in Canada is somewhat clearer.  There is a notice in  

the Canada Air Pilot (the document that contains all the publicly  

available instrument approach procedures) which clearly states that  

TSO'd equipment is required to fly GPS approaches.  This notice is  

reprinted in Aeronautical Information Circular 27/05 in the Canadian  

Aeronautical Information Manual.



http://tinyurl.com/y442ct



Kevin Horton



On 6 Jan 2007, at 09:52, BobsV35B(at)aol.com wrote:



 	  Quote: 	
		   Good Morning Kevin,



 I am definitely stepping out from my area of expertise here, but is  

 a TSO required for operations of a home built aircraft?



 It isn't even required for all operations of certificated aircraft.



 The determination of the equipment that is required for IFR flight  

 appears to be left up to the operator. As long as the operator  

 determines that the equipment meets the standards required for IFR  

 flight, the stuff should be acceptable.



 What do you feel is required?



 Happy Skies,



 Old Bob

 AKA

 Bob Siegfried

 Ancient Aviator

 Stearman N3977A

 Brookeridge Air Park LL22

 Downers Grove, IL 60516

 630 985-8503



 In a message dated 1/6/2007 6:26:49 A.M. Central Standard Time,  

 khorton01(at)rogers.com writes:

 I'd ask to see a copy of the letters from the FAA that confirm the

 TSOs have been issued.

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