Cheapest IFR GPS setup (Feb 2010)

dmccormack said:
Hmmm..it seems the download/install log for the Jepp updates would be evidence enough....

:dunno:
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This was discussed a long time ago.

This is what I found out by calling my FSDO
smigaldi said:
Called the FSDO again today about this topic to see if we could get to the bottom of it. They took the issue and discussed internally for about an hour and called me back. The bottom line is that they could not agree either. It seems the issue comes down to interpreting whether the database upgrade is maintainence or a service. Those who believed it to be service said a log entry was not required and those who believed it to be maintenance said there needed to be a log entry. They also noted that those who felt it was maintenance were the ones that used to do FMS updates for part 135 and 121 equipment were it is most definitely a log entry requirement.

So there is our answer it is or is not required depending on who does you ramp check. :rofl:

I think to be on the safe side I will probably start doing it in a separate log book.
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And this is the link to the whole thread
http://www.pilotsofamerica.com/forum/showthread.php?t=4622&
 
Ron Levy said:
To update the card on any model installed GPS, even VFR-only. See item (32) in section (c) of Appendix A to Part 43, and 43.9(a) -- updating your installed GPS database is preventive maintenance which must be logged. So far, the FAA is only informing folks about that, but they've been doing so for a couple of years now, and eventually the day will come when they will move to enforcing instead of informing. Personally, I keep track of GPS updates in a little "avionics log" in my glove box, where I also track 91.171 VOR checks, but that's not the only acceptable solution.
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I also have such an auxiliary log..somewhere in the baggage area...but I find it a little overboard the FAA calling it MX function...its like taking the face of of a cd player or something.
 
taters said:
I also have such an auxiliary log..somewhere in the baggage area...but I find it a little overboard the FAA calling it MX function...its like taking the face of of a cd player or something.
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More like logging replacing sectional maps -- it's data, not a part or function.
 
Ron Levy said:
That works for routine IFR flying if there's a data card in the unit (if not, there's no data to verify), but isn't acceptable for an IR practical test or IPC because the IR PTS specifically requires a current database if you have an IFR GPS installed.
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In the event of a pending IPC or Instrument check ride with a data card that is out of date, just make a log book entry and inop the GPS for IFR. Simple.
 
Ron Levy said:
To update the card on any model installed GPS, even VFR-only. See item (32) in section (c) of Appendix A to Part 43, and 43.9(a) -- updating your installed GPS database is preventive maintenance which must be logged. So far, the FAA is only informing folks about that, but they've been doing so for a couple of years now, and eventually the day will come when they will move to enforcing instead of informing. Personally, I keep track of GPS updates in a little "avionics log" in my glove box, where I also track 91.171 VOR checks, but that's not the only acceptable solution.
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This seems pretty crazy. I pull my 430W card each month before it expires, bring it home and update and reinstall it just like a few thousand people do each month. The updated and current database shows each time the unit is powered up, so isn't it obvious whether or not the database is current?

Now the question is can I finally kill my ADF off before my IR checkride so I don't have to do NDB work? :mad2:
 
DutchessFlier said:
Now the question is can I finally kill my ADF off before my IR checkride so I don't have to do NDB work? :mad2:
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that stuff is good for you!...I know it sucks but after your IR ride you are free to never do them again.

If you really want to you can inop the adf...some examiners around here request that it be done.
 
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Those who believed it to be service said a log entry was not required
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That's my story and I'm sticking to it until the FAA publishes something different. The whole idea of logging something as simple as swapping cards or downloading from a laptop is ludicrous IMO. Some day these updates might be automatically downloaded via satellite, who's gonna log it then?
 
gismo said:
That's my story and I'm sticking to it until the FAA publishes something different. The whole idea of logging something as simple as swapping cards or downloading from a laptop is ludicrous IMO. Some day these updates might be automatically downloaded via satellite, who's gonna log it then?
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For Part 91 Ops I wouldn't be too concerned, I haven't seen anything that says otherwise.
 
gismo said:
But I have that now!
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Yep! I suppose the argument could be made that you have no record that you actually "installed" the update.

This whole argument seems weak, given that enforcement action based on expired paper charts is what percentage of total actions?
 
taters said:
A Garmin 155XL is still a decent option...Fully IFR certified..I just had a demo unit put in a Bonanza to replace the worthless KLN-90A. Less that 3k installed. I have seen many of these units (new or refurbished) far below retail at many avionics shops..
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I think you got a very rare and lucky deal--enjoy. The rest of us are looking at $4K installed, minimum.
 
EdFred said:
I flew my 430 for over a month before I was able to finally get it flight checked for use under IFR. It had this little sticker FROM THE FACTORY saying "For VFR use only."

What's the examiner going to check?
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The AFM Supplement for the GPS. If the IFR flight check hasn't been done, it will say "VFR only." After the flight check, it is replaced with one approving IFR operations.
 
EdFred said:
Prove I took it out
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OK, so your question is not legality, but whether or not anyone can prove you broke this rule? That's not my department.
and what preventative maintenance am I doing?
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Just what it says in item 31 of the preventive maintenance list in Appendix A to Part 43:
Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)).
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taters said:
I also have such an auxiliary log..somewhere in the baggage area...but I find it a little overboard the FAA calling it MX function...its like taking the face of of a cd player or something.
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Perhaps, but as I understand it, the alternative to making it preventive maintenance you can do yourself was to make it maintenance of a radio that had to be done by a certified avionics repair station. Remember -- it's the FAA.
 
Rotor&Wing said:
In the event of a pending IPC or Instrument check ride with a data card that is out of date, just make a log book entry and inop the GPS for IFR. Simple.
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You should read the new IR PTS. The installed GPS must be disabled and logged as such by an authorized repairman, not just stickered and logged "inop" by the owner. Then, after the ride, you'll need to go back to the shop to get that all undone. If you are so anxious to avoid getting a current database that you want to go through all that, mighty fine, but it's gonna cost you -- maybe more than it costs to update the database.
 
DutchessFlier said:
This seems pretty crazy. I pull my 430W card each month before it expires, bring it home and update and reinstall it just like a few thousand people do each month. The updated and current database shows each time the unit is powered up, so isn't it obvious whether or not the database is current?
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I can't speak to the "why," only the "what."
Now the question is can I finally kill my ADF off before my IR checkride so I don't have to do NDB work?
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Sure -- have it removed by an authorized repairman with the proper log entries and W&B/equipment list changes.
 
gismo said:
That's my story and I'm sticking to it until the FAA publishes something different. The whole idea of logging something as simple as swapping cards or downloading from a laptop is ludicrous IMO. Some day these updates might be automatically downloaded via satellite, who's gonna log it then?
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It's black-letter law, Lance, so the FAA already has "published something different" -- just read the regs I referenced. OTOH, Scott's info came from a couple of uninformed FSDO folks. If you ask HQ (Legal or Flight Standards), you're going to be told the log entries are required. Choose wisely.
 
Ron Levy said:
OK, so your question is not legality, but whether or not anyone can prove you broke this rule? That's not my department.
Just what it says in item 31 of the preventive maintenance list in Appendix A to Part 43:
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Again, what preventative maintenance am I doing to the unit? Simply removing is is not performing any maintenance on it.

Note that it says removing AND replacing, not removing and putting the same unit back.
 
Ron Levy said:
Only if it includes your name, signature, and certificate type/number. Ref: 14 CFR 43.9(a).
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I don't update the database, I replace it. 43 does not address replacing the database.
 
EdFred said:
Again, what preventative maintenance am I doing to the unit? Simply removing is is not performing any maintenance on it.

Note that it says removing AND replacing, not removing and putting the same unit back.
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It's there in black and white, Ed. By FAA regulation, removing and replacing (i.e., returning it to its original place) the unit is "preventive maintenance" and requires a log entry. Do otherwise at your own risk.
 
EdFred said:
Again, what preventative maintenance am I doing to the unit? Simply removing is is not performing any maintenance on it.

Note that it says removing AND replacing, not removing and putting the same unit back.
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Read part 43, Appendix A, (c) 31 and 32, excerpted below. The appendix defines what preventative maintenance is in terms of work performed. Any work on your aircraft included in the list is defined as preventative maintenance:


Appendix A to Part 43 - Major Alterations, Major Repairs, and Preventive Maintenance

...

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

...

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.
(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.
 
dmccormack said:
There's been an enforcement action on this topic?
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To my knowledge, not yet -- nobody's been silly enough to argue that putting a radio back in the tray from whence it came is not "replacing" it.
My guess is the ALJ would have the FAA Counsel aside and let him know not to waste time with frivolities.
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Since the ALJ is legally bound to accept the FAA Counsel's interpretations of the FAR's, that won't happen unless the ALJ likes being overruled on appeal.
 
John Collins said:
Read part 43, Appendix A, (c) 31 and 32, excerpted below. The appendix defines what preventative maintenance is in terms of work performed. Any work on your aircraft included in the list is defined as preventative maintenance:


Appendix A to Part 43 - Major Alterations, Major Repairs, and Preventive Maintenance

...

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

...

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.
(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.
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It is still not required for the kln90B to make a log entry!:rolleyes:
 
John Collins said:
Read part 43, Appendix A, (c) 31 and 32,
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I've read it, many times, and disagree with it being as black and white as Ron claims it is. Especially since preventive maintenance in 1.1 doesn't coincide exactly with 43.

1.1:

Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

I'm not performing any "minor preservation" and I am not replacing any "small standard parts" when I take out the GPS, and put it back.
 
While Ron's take on the regs does defy common sense, the FAA is in the habit of doing just that. In my contemplation of IFR gear for the Free Bird I certainly have new issues to consider. Great thread.
 
EdFred said:
I've read it, many times, and disagree with it being as black and white as Ron claims it is. Especially since preventive maintenance in 1.1 doesn't coincide exactly with 43.

1.1:

Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

I'm not performing any "minor preservation" and I am not replacing any "small standard parts" when I take out the GPS, and put it back.
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I guess there is no hope for you.
 
Tell you what, Ed -- if you're so sure of your interpretation, you send a letter to the following address:

Office of the Chief Counsel
800 Independence Avenue SW
Washington, DC 20591

...describing how you took your GPS out of the panel, carried it home, and then put it back in without entering that in the aircraft's maintenance records. Be sure to give your full name, pilot certificate number, address, aircraft N-number, and the dates involved, and sign the letter. Then let me know what happens.
 
If it's like the last three times I've written the Chief Counsel, I expect them to do nothing. I've been waiting over 3 years for regulation interpretations. I think I'm quite safe.
 
steingar said:
While Ron's take on the regs does defy common sense, the FAA is in the habit of doing just that. In my contemplation of IFR gear for the Free Bird I certainly have new issues to consider. Great thread.
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It's pretty simple: Some argue that updating the Nav data chip in the 430 requires a log entry.

Other are arguing that there is no such requirement.

I think the third way is that there is plentiful evidence of a chip being updated or not should some accident hinge on an update -- the SkyBound logs, the data on the chip, and the IP logs for the computer used to download the data.

For option 3, I think there's plenty of "logging," without requiring a handwritten entry ala "I installed the May 22, 2010 update on this date, signed me"
 
dmccormack said:
It's pretty simple: Some argue that updating the Nav data chip in the 430 requires a log entry.

Other are arguing that there is no such requirement.

I think the third way is that there is plentiful evidence of a chip being updated or not should some accident hinge on an update -- the SkyBound logs, the data on the chip, and the IP logs for the computer used to download the data.

For option 3, I think there's plenty of "logging," without requiring a handwritten entry ala "I installed the May 22, 2010 update on this date, signed me"
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Not to mention is it when you d/l from Jeppesen, or when you actually swap cards in the plane? Rarely if ever are they on the same day for me.

"Maintenance started February 6th, 2010, completed February 15th, 2010"

Riiiiiiiiiiiiiiiiiiiiight.
 
EdFred said:
Not to mention is it when you d/l from Jeppesen, or when you actually swap cards in the plane? Rarely if ever are they on the same day for me.

"Maintenance started February 6th, 2010, completed February 15th, 2010"

Riiiiiiiiiiiiiiiiiiiiight.
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I suppose Garmin could fix all this by providing Satellite download or -- better yet -- USB data load (instead of these ridiculously expensive, single use "chips")
 
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