wsuffa
Touchdown! Greaser!
I've been following an issue on another aviation board concerning this topic. Short story, ATC denied a pilot a VOR/DME approach with the DME OTS, despite the pilot having and requesting to use a certified GPS in lieu of DME. The pilot bounced it up the chain, and got this reply from the FAA today:
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quote
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The Southern Region Air traffic Division, Airspace and Procedures Branch, has reviewed the situation you described below.
Situation: A pilot was cleared for the ILS or LOC RWY 36 Instrument Approach Procedure (IAP) at Tupelo Regional Airport (TUP), Tupelo, MS, by Memphis ARTCC; but was denied a request for the VOR/DME RWY 18 IAP under Instrument Flight Rules (IFR) because the DME was out of service. The pilot cancelled IFR and was transferred to the control tower. The control tower refused to clear the aircraft for the VOR/DME RWY 18 under Visual Flight Rules (VFR). The pilot advised he had certified GPS equipment aboard the aircraft.
Subsequently, the pilot contacted Memphis ARTCC requesting an explanation. The pilot was advised that in accordance with the Aeronautical Information Manual 1-1-19, e., 3., (page 1-1-30) the IAP at TUP was not in the GPS Approach Overlay Program and that no authorization to use GPS avionics was in place. The pilot cited Aeronautical Information Manual, paragraph 1-1-19., f. (page 1-1-31), which outlines the procedures for utilizing GPS in lieu of ADF and DME.
Request clarification of this situation. Must an IAP be included in the GPS Approach Overlay Program and be identified by the name "or GPS" for the pilot to use the provisions of AIM, paragraph 1-1-19., f. ?
Findings: The Air Traffic Division agrees with the interpretation provided to you by Memphis ARTCC for the following reasons:
Aeronautical Information Manual, paragraph 1-1-19, e., 3., (page 1-1-30) is a sub-paragraph under paragraph 1-1-19, Use of GPS for IFR Oceanic, Domestic En Route and Terminal Area Operations. Sub-paragraph e., 3. outlines the GPS Approach Overlay Program which was cited by Memphis ARTCC.
Paragraph f., Use of GPS in lieu of ADF and DME, is a separate paragraph which addresses (a) Operations allowed and (b) Restrictions.
Sub-paragraph f., (a), (1) Determining the aircraft position over a DME fix, is restricted to at or above 24,000 feet mean sea level.
Sub-paragraph f., (b), (3) states waypoints must be retrieved from the GPS airborne database. If the required positions cannot be retrieved from the airborne database, the substitution of GPS for ADF and/or DME is not authorized.
As the VOR/DME RWY 18 IAP is not in the GPS Overlay Program, the missed approach point, Tupelo VOR/DME (OTB) 3.6 DME, is not in the GPS airborne database.
Therefore, it is determined that IAP's must be in the overlay program and all waypoints must be contained in the airborne database to substitute GPS for ADF/DME.
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end quote
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THe approach is here:
http://download.aopa.org/iap/200507..._dme_rwy_18.pdf
THe AOPA fact sheet on gps in lieu of dme/adf is here:
http://www.aopa.org/whatsnew/air_tr...ps_in_lieu.html
And the AIM section is here:
http://www.aopa.org/members/files/a...r_1.html#1-1-19
My prior understanding of the in-lieu-of procedures was the same as the AOPA document and the procedure outlined in the AIM.
The FAA's interpertation is wrong on a couple of counts.
First, Section 1-1-19(f)(1)(a)(1) is not limited to FL240 and above. The text of that section says:
"(1) Determining the aircraft position over a DME fix. GPS satisfies the 14 CFR Section 91.205(e) requirement for DME at and above 24,000 feet mean sea level (MSL) (FL 240). "
In other words, it's legal to determine aircraft position. And, since the rule require DME above FL240, the GPS can substitute.
Second, the remaining logic in the FAA interpertation is in conflict with 1-1-19(f)(1)(c), to wit:
(quote)
(1) To determine the aircraft position over a DME fix:
[a] Verify aircraft GPS system integrity monitoring is functioning properly and indicates satisfactory integrity.
If the fix is identified by a five letter name which is contained in the GPS airborne database, you may select either the named fix as the active GPS waypoint (WP) or the facility establishing the DME fix as the active GPS WP.
NOTE-
When using a facility as the active WP, the only acceptable facility is the DME facility which is charted as the one used to establish the DME fix. If this facility is not in your airborne database, you are not authorized to use a facility WP for this operation.
[c] If the fix is identified by a five letter name which is not contained in the GPS airborne database, or if the fix is not named, you must select the facility establishing the DME fix or another named DME fix as the active GPS WP.
NOTE-
An alternative, until all DME sources are in the database, is using a named DME fix as the active waypoint to identify unnamed DME fixes on the same course and from the same DME source as the active waypoint.
CAUTION-
Pilots should be extremely careful to ensure that correct distance measurements are used when utilizing this interim method. It is strongly recommended that pilots review distances for DME fixing during preflight preparation.
(end quote)
This is not limited to use above FL240, nor is it limited to ILS/LOC systems. It plainly says that you may use the facility establishing the DME fix. In this case, that facility is the Tupelo VOR.
Also, the AIM 1-1-19(f)(1) says:
"The ground-based NDB or DME facility may be temporarily out of service during these operations."
Since you can establish the Tupelo VOR, and you have a legal IFR-approved GPS, you are legal to shoot the approach.
By this logic, you can't subsitute the GPS for an NDB/ADF, either.
The upshot? Apparently in Memphis area, you will be denied any approaches if you are using GPS in lieu of the DME, or if the DME navaid is OTS.
I say that's contrary to what AOPA claims, and it's contrary to the AIM. But ATC is apparently the enforcer here. Y'all ready to pony up for a DME?
Flyer beware.
Sigh.
Comments?
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quote
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The Southern Region Air traffic Division, Airspace and Procedures Branch, has reviewed the situation you described below.
Situation: A pilot was cleared for the ILS or LOC RWY 36 Instrument Approach Procedure (IAP) at Tupelo Regional Airport (TUP), Tupelo, MS, by Memphis ARTCC; but was denied a request for the VOR/DME RWY 18 IAP under Instrument Flight Rules (IFR) because the DME was out of service. The pilot cancelled IFR and was transferred to the control tower. The control tower refused to clear the aircraft for the VOR/DME RWY 18 under Visual Flight Rules (VFR). The pilot advised he had certified GPS equipment aboard the aircraft.
Subsequently, the pilot contacted Memphis ARTCC requesting an explanation. The pilot was advised that in accordance with the Aeronautical Information Manual 1-1-19, e., 3., (page 1-1-30) the IAP at TUP was not in the GPS Approach Overlay Program and that no authorization to use GPS avionics was in place. The pilot cited Aeronautical Information Manual, paragraph 1-1-19., f. (page 1-1-31), which outlines the procedures for utilizing GPS in lieu of ADF and DME.
Request clarification of this situation. Must an IAP be included in the GPS Approach Overlay Program and be identified by the name "or GPS" for the pilot to use the provisions of AIM, paragraph 1-1-19., f. ?
Findings: The Air Traffic Division agrees with the interpretation provided to you by Memphis ARTCC for the following reasons:
Aeronautical Information Manual, paragraph 1-1-19, e., 3., (page 1-1-30) is a sub-paragraph under paragraph 1-1-19, Use of GPS for IFR Oceanic, Domestic En Route and Terminal Area Operations. Sub-paragraph e., 3. outlines the GPS Approach Overlay Program which was cited by Memphis ARTCC.
Paragraph f., Use of GPS in lieu of ADF and DME, is a separate paragraph which addresses (a) Operations allowed and (b) Restrictions.
Sub-paragraph f., (a), (1) Determining the aircraft position over a DME fix, is restricted to at or above 24,000 feet mean sea level.
Sub-paragraph f., (b), (3) states waypoints must be retrieved from the GPS airborne database. If the required positions cannot be retrieved from the airborne database, the substitution of GPS for ADF and/or DME is not authorized.
As the VOR/DME RWY 18 IAP is not in the GPS Overlay Program, the missed approach point, Tupelo VOR/DME (OTB) 3.6 DME, is not in the GPS airborne database.
Therefore, it is determined that IAP's must be in the overlay program and all waypoints must be contained in the airborne database to substitute GPS for ADF/DME.
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end quote
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THe approach is here:
http://download.aopa.org/iap/200507..._dme_rwy_18.pdf
THe AOPA fact sheet on gps in lieu of dme/adf is here:
http://www.aopa.org/whatsnew/air_tr...ps_in_lieu.html
And the AIM section is here:
http://www.aopa.org/members/files/a...r_1.html#1-1-19
My prior understanding of the in-lieu-of procedures was the same as the AOPA document and the procedure outlined in the AIM.
The FAA's interpertation is wrong on a couple of counts.
First, Section 1-1-19(f)(1)(a)(1) is not limited to FL240 and above. The text of that section says:
"(1) Determining the aircraft position over a DME fix. GPS satisfies the 14 CFR Section 91.205(e) requirement for DME at and above 24,000 feet mean sea level (MSL) (FL 240). "
In other words, it's legal to determine aircraft position. And, since the rule require DME above FL240, the GPS can substitute.
Second, the remaining logic in the FAA interpertation is in conflict with 1-1-19(f)(1)(c), to wit:
(quote)
(1) To determine the aircraft position over a DME fix:
[a] Verify aircraft GPS system integrity monitoring is functioning properly and indicates satisfactory integrity.
If the fix is identified by a five letter name which is contained in the GPS airborne database, you may select either the named fix as the active GPS waypoint (WP) or the facility establishing the DME fix as the active GPS WP.
NOTE-
When using a facility as the active WP, the only acceptable facility is the DME facility which is charted as the one used to establish the DME fix. If this facility is not in your airborne database, you are not authorized to use a facility WP for this operation.
[c] If the fix is identified by a five letter name which is not contained in the GPS airborne database, or if the fix is not named, you must select the facility establishing the DME fix or another named DME fix as the active GPS WP.
NOTE-
An alternative, until all DME sources are in the database, is using a named DME fix as the active waypoint to identify unnamed DME fixes on the same course and from the same DME source as the active waypoint.
CAUTION-
Pilots should be extremely careful to ensure that correct distance measurements are used when utilizing this interim method. It is strongly recommended that pilots review distances for DME fixing during preflight preparation.
(end quote)
This is not limited to use above FL240, nor is it limited to ILS/LOC systems. It plainly says that you may use the facility establishing the DME fix. In this case, that facility is the Tupelo VOR.
Also, the AIM 1-1-19(f)(1) says:
"The ground-based NDB or DME facility may be temporarily out of service during these operations."
Since you can establish the Tupelo VOR, and you have a legal IFR-approved GPS, you are legal to shoot the approach.
By this logic, you can't subsitute the GPS for an NDB/ADF, either.
The upshot? Apparently in Memphis area, you will be denied any approaches if you are using GPS in lieu of the DME, or if the DME navaid is OTS.
I say that's contrary to what AOPA claims, and it's contrary to the AIM. But ATC is apparently the enforcer here. Y'all ready to pony up for a DME?
Flyer beware.
Sigh.
Comments?
