Message-ID: <519194EBBDF7D2118C6000A0CC412E33080F25@EXCHANGE>
From: Jeffrey Skiba <jskiba@ICOSA.NET>
To: lancair.list@olsusa.com
Subject: RE: More IFR GPS questions and 337 forms
Date: Tue, 13 Mar 2001 14:33:51 -0600
Reply-To: lancair.list@olsusa.com
Mime-Version: 1.0

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Jeff,

Thanks for the digging.

Were you using an older AIM?  In my 2001 AIM (McGraw Hill) the pertinent 
paragraph is 1-1-21 b.1.(a) and contains additional limitations.

I was using the AOPA on-line version but I have just looked at the FAA
ON-Line AIM with CHANGE 2 dated Jan 25 2001 and I do not see what you are
getting at? Is it the section on integrity monitoring (RAIM)?

Also I am pasting the following e-mail sent to me from Randy Hansen EAA
Government & Industry Relations Specialist at the EAA:

FAA policy can be applied to aircraft other than experimental where the
builder is the "manufacturer" and is responsible for ensuring the safety of
persons and property on the surface and other aircraft in flight. The
experimental amateur-built aircraft builder ensures the safety through the
phase I test flights and logbook entries stating that his/her aircraft is in
a safe condition.

Typically, FAA policy's like this are passed to amateur-built aircraft
owners through instructions contained within the operating limitations.
Since they are not there now, our procedures in #4, are viable. 

The #4 are the steps that you must take to ensure your aircraft can be
operated safety "throughout its normal range of speeds and throughout all
the maneuvers to be executed" - the key is the "maneuvers" portion of that
statement - and conducting an IFR GPS approach is one of the maneuvers you
will be executing.

>We've gone back to the research "lab" and this is the answer to

> your flying IFR with a GPS
> 
> 1. As stated earlier (below) AIM, paragraph 1-1-21, lists the
> "preferred" FAA method for flying IFR with a GPS. That "preferred"
> method includes a statement, in AIMs, "hand-held GPS devises are not
> authorized for IFR flight."
> 
> 2. The same paragraph in the AIM refers to GPS having or meeting the
> requirements of TSO C-129 and AC 20-138.
> 
> 3. Like you, EAA has not found any FAR that states "hand-held" GPS
> devices shall not be used for IFR flight. EAA even went to FAA
> headquarters for further guidance.
> 
> 4. The answer or bottom line:
> 
> As an experimental amateur-built aircraft you must certify your
> aircraft and all the equipment on board the aircraft (per 91.319(b))
> that: (1) Your "aircraft is controllable throughout its normal range
> of speeds and throughout all the maneuvers to be executed; and (2) The
> aircraft has no hazardous operating characteristics or design
> features."
> 
> That certification is accomplished when you sign your experimental
> amateur-built aircraft airworthiness application (FAA Form 8130-6),
> and verified through the phase I test flights and the resulting
> logbook sign-off - as required by your FAA issued operating
> limitations.
> 
> The test flight hours listed in your operating limits are recommended
> minimums, so if you need more hours to complete your aircraft's
> "certification" for flight into IFR conditions (must be done VFR),
> including "certifying" your IFR equipment (GPS, etc.) you need to
> extend those hours to meet your requirements. You may even need to go
> back to the FAA FSDO or MIDO to modify your test flight area in order
> to fly GPS (or other NAVAID) approaches. If you can certify your
> hand-held GPS as "having no hazardous operating characteristics or
> design features throughout all the maneuvers you will be executing",
> per the FAA "guidance" listed in TSO C-129 and AC 20-138, then just
> make a logbook entry stating that fact.
> 
> If the GPS system you are using was added after you completed your
> initial phase I test flights or you purchased a used experimental
> amateur-built aircraft and added a GPS system, then you must:
> 
> 1. Per your operating limitations determine if the change or addition
> of the GPS and its antenna's meet the "major change" rule. If they
> do, comply per your operating limitations. If not, or in either case,
> as the owner of the experimental amateur-built aircraft you are still
> responsible for certifying your GPS (or other NAVAID) as "having no
> hazardous operating characteristics or design features throughout all
> the maneuvers you will be executing" and making the appropriate
> logbook entry stating that.
> 
> 2. To "certify" your new installation requires you to place your
> aircraft into a test flight phase to prove the installation of the
> system and it's effect on the aircraft's other systems are safe, and
> will not pose a hazard to persons or property on the surface. The
> test flight must be done in VFR conditions, with no visibility
> reducing devices (foggels, etc.), no passengers, and flown on actual
> GPS approaches. You make the determination of the test flight hours
> necessary to make that determination.
> 
> 3. Once the test flights are finished and you make the appropriate
> logbook entries certifying to the airworthiness of the system, you
> place yourself back into the phase II normal flights.
> 
> 4. There is no requirement for the FAA to approve or sign-off your
> GPS system. As the owner of an experimental amateur-built aircraft,
> that is your responsibility.
> 
> Your amateur-built aircraft's operating limitations contains
> references to FAR's that must be complied with or met "with the scope
> and detail" of those FAR's. This is no different, the TSO and the AC
> are the FAA "guidelines" for GPS operations within the National
> Airspace System, and you must certify that your GPS system meets those
> guidelines and your aircraft is in a condition for safe operation and
> will not be a hazard to persons/property on the ground or other
> aircraft operating within the National Airspace System.


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