Log your GPS database updates

stapler101

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stapler101
A friend just received a letter from the FAA that he was being violated for not logging his gps updates.
He has been told that VFR gps's do not have to be updated, but if they are updated, you must log it.
If not updated, it must have a placard.
The FAA quotes 43.9 (I believe that is the correct reg in the letter).
This applies only to panel mounted units.
 
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A friend just received a letter from the FAA that he was being violated for not logging his gps updates.
The FAA has been warning folks about this for several years. I guess they've moved from warning to enforcing.

He has been told that VFR gps's do not have to be updated, but if they are updated, you must log it.
If not updated, it must have a placard.
The FAA quotes 43.9 (I believe that is the correct reg in the letter).
This applies only to panel mounted units.
All correct. Per 14 CFR 43 Appendix A paragraph (c) item (32), updating the database in an installed GPS is "preventive maintenance."
(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.
Per 43.9(a), all preventive maintenance must be logged.
Sec. 43.9

Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, Sec. 135.411(a)(1), and Sec. 135.419 of this chapter).

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.
The good news is that per 43.3(), this preventive maintenance can be done by any pilot above Student Pilot (although Sport Pilots may only do this on LSA's).
Sec. 43.3

Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.

(a) Except as provided in this section and Sec. 43.17, no person may maintain, rebuild, alter, or perform preventive maintenance on an aircraft, airframe, aircraft engine, propeller, appliance, or component part to which this part applies. Those items, the performance of which is a major alteration, a major repair, or preventive maintenance, are listed in appendix A.
...
(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

Here's about what your entry should look like:
11/22/11, tach time 2345.6. Updated GPS database IAW Garmin xxx manual. Ops checked OK. /s/ Joe Pilot, 3456890, Pvt Pilot.

While you can put this in the airframe log, you can also have a separate log you keep in the plane for GPS updates and 91.177 VOR checks. I have a little pocket notebook for that in my glove box.
 
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A friend just received a letter from the FAA that he was being violated for not logging his gps updates.
He has been told that VFR gps's do not have to be updated, but if they are updated, you must log it.
If not updated, it must have a placard.
The FAA quotes 43.9 (I believe that is the correct reg in the letter).
This applies only to panel mounted units.

There must be more to this story... How could they possibly know?


Paul
 
could be he just got ramp checked

Even if ramp checked, the inspector is not authorized to go into the aircraft without the pilot's permission and any log information does not need to be provided at the time of the ramp check. So unless the pilot invited the inspector into the aircraft, it would be hard to establish that the database had been updated or if so, by whom.
 
A friend just received a letter from the FAA that he was being violated for not logging his gps updates.
He has been told that VFR gps's do not have to be updated, but if they are updated, you must log it.
If not updated, it must have a placard.
The FAA quotes 43.9 (I believe that is the correct reg in the letter).
This applies only to panel mounted units.

There is no requirement to placard a GPS indicating that the database has not been updated although there is a requirement for a VFR Only GPS to be so placarded at installation time. There is no requirement to update a VFR database and flight with an outdated database is permitted on an IFR GPS.

If one does update the database, this is preventive maintenance and a maintenance record must be made prior to flight. FAR 91.417 (b) specifies how long the maintenance record must be kept, which in this case is one year or until the work is superseded. There is no requirement that the maintenance record be kept in the permanent maintenance records which is usually in the log books. I keep mine on a piece of paper that I keep in the glove box. I would not share the record at the time of a ramp inspection and the inspector has no authority to look at it at that point in time or enter my aircraft. The inspector may request I produce the log record at a mutually acceptable point in time in the future.
 
My WAG is an FAA type while viewing the aircraft at either mx shop or on the ramp had noticed the GPS installed and no placard. He then dug a bit further into the logs because he has a feather up his butt for precisely this thing. If on ramp, innocent pilot playing nice invited it on himself.
 
There is no requirement to placard a GPS indicating that the database has not been updated...
There is a required placard that a GPS is VFR only if data not current, correct?

(OP only implies this GPS is VFR. He doesn't exactly state if this GPS is otherwise IFR certified.)
 
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How does an installed VFR GPS differ from a handheld GPS?

Is there any function, clearance, or routing that can accomplished with an installed VFR GPS that cannot be accomplished with a handheld GPS?

Is there any function, clearance, or routing that is enabled by using an installed VFR GPS that cannot be accepted or performed in the same aircraft without the VFR GPS?

feh - logging updates to a VFR GPS is a bit over the top.

What's next, logging everytime we wash bugs off the windshield?
 
Even if ramp checked, ... any log information does not need to be provided at the time of the ramp check.
Not quite correct. If you have the log with you, you must produce it on demand, even if you're not required to have it with you. Of course, you can always lie about having it, but lying to Federal officials in the performance of their duty is highly inadvisable.

In any event, it appears that the FAA is finally checking and enforcing this rule. Given the ease and simplicity of compliance, I suggest complying.
 
There is a required placard that a GPS is VFR only if data not current, correct?

(OP only implies this GPS is VFR. He doesn't exactly state if this GPS is otherwise IFR certified.)

No. The placard that is required is for a GPS that is VFR Only or an IFR capable GPS that is installed as VFR Only. The database status is not a criteria for the placard.
 
There is a required placard that a GPS is VFR only if data not current, correct?
No. You are not required to have a current database to use an IFR-approved GPS for IFR purposes. See AIM Sections 1-1-19 and 1-2-3.

(OP only implies this GPS is VFR. He doesn't exactly state if this GPS is otherwise IFR certified.)
If the installed GPS is not IFR-approved, it must be placarded "VFR only." Absence of a VFR-only placard implies IFR approval. But IFR or VFR, all database updates must be logged.
 
How does an installed VFR GPS differ from a handheld GPS?
The difference is that it is installed, and the installation must be done IAW approved data and logged in the aircraft maintenance records.

Is there any function, clearance, or routing that can accomplished with an installed VFR GPS that cannot be accomplished with a handheld GPS?
No, but irrelevant to the update logging issue.

Is there any function, clearance, or routing that is enabled by using an installed VFR GPS that cannot be accepted or performed in the same aircraft without the VFR GPS?
No, but irrelevant to the update logging issue.

feh - logging updates to a VFR GPS is a bit over the top.
The alternative to making it preventive maintenance you can do yourself would be making it "regular" maintenance requiring an avionics shop. Given that choice, I'll take "preventive maintenance" even if it means keeping my little notepad in my glove box and writing two sentences in it every four weeks.

What's next, logging everytime we wash bugs off the windshield?
That's servicing, not maintenance, and thus doesn't have to be logged.

Y'all may think this is silly, or annoying, or anything else you want, but the FAA has been reminding of this requirement for several years, and now it appears they're enforcing it. Their game, your choice -- play by the rules or be sidelined.
 
Is it just me or is the nitpick-enest "enforcement" ever?

A log of a VFR DB updates? Really? Why? Who cares? What's the impact? How is flight safety affected by the log entry?

And I really don't care if "them's the rules." Sometimes the rules are plain stupid, and anyone unwilling to admit same is just as stupid.

Disclaimer: The only panel mounted GPS I've flown behind have been IFR certified and the updates were logged -- flying approaches it's good to have the latest data. The only VFR GPS I've used have been handheld (the earliest was a Garmin GPS II Plus with only user waypoints). I don't log updates to my BlackBerry, either.
 
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No. The placard that is required is for a GPS that is VFR Only or an IFR capable GPS that is installed as VFR Only. The database status is not a criteria for the placard.

An out-of-date GPS DB can still be used in IFR for enroute navigation if the PIC validates that the waypoints being used are current.
 
The "aircraft records" do not need to be all the same log book (in fact, they usually aren't, most people have separate log books for the Engine, Prop, and Airframe).

I keep a small notebook in the plane where I log the VOR checks and the database updates. Make sure you use the proper form for which ever one you are doing. Of course, I "ditto mark" most of the entries other than the date and my signature.
 
Is it just me or is the nitpick-enest "enforcement" ever?

A log of a VFR DB updates? Really? Why? Who cares? What's the impact? How is flight safety affected by the log entry?

And I really don't care if "them's the rules." Sometimes the rules are plain stupid, and anyone unwilling to admit same is just as stupid.
So, when you're giving folks training, are you going to skip telling them about this rule and how to comply with it?
 
No. You are not required to have a current database to use an IFR-approved GPS for IFR purposes. See AIM Sections 1-1-19 and 1-2-3.
As a side note, it appears your reference to the AIM is evidence the AIM is in fact regulatory. Some persons have debated that.:(
 
So, when you're giving folks training, are you going to skip telling them about this rule and how to comply with it?

Newsflash: there are plenty of rules that are ignored by the citizenry and the courts until there's been some infraction and the legal folks start searching the stacks and find these gems.

I can guarantee that you have broken several tax laws in the last 5 years -- just like every other citizen -- unless you have an active IRS Tax attorney and accountant on retainer. Oh -- and even they may disagree.

My advice to any owner I fly with is "Log anything you do to this airplane -- you can't be faulted for over-compliance." I do the same.

That said, I admit this is a weasel, CYA approach that won't stand up if the feds are truly after you -- there's always some infraction just one more dig away.

And the case cited by the OP is clearly one of those. There's some other infraction that brought this one to light.

The danger posed by your "It's their ball game" approach is that in fact it's NOT "their ball game." It's our ball game, our field, our ball, our rules, our refs.

The FAA is a creation of the republic and every single law on the books is subject to being overturned (see US Constitution for more). So when this sort of nitpicky nonsense drives our behavior we need to step back and say, "Wait a second -- is this what we want?" And if the answer is "no," then start doing something about it.

Senator Inhofe's Pilot's Bill of Rights is a step in the right direction:

“The support this bill has received, including a majority of the members of the Senate Commerce Committee, is indicative of the common sense approach to correcting problems faced by General Aviation pilots. We are seeking to give pilots access to evidence that is being used against them while ending the guilty-until-proven-innocent approach that the FAA has taken, improve the Notice To Airmen (NOTAM) system, and correct problems with the pilot medical certification process. I look forward to this being taken up and passed in the Senate in the near future.” Details about the Pilot’s Bill of Rights
ØRequires that in an FAA enforcement action against a pilot, the FAA must grant the pilot all relevant evidence 30 days prior to a decision to proceed with an enforcement action. This is currently not done and often leaves the pilot grossly uninformed of his violation and recourse.
ØClarifies statutory deference as it relates to National Transportation Safety Board (NTSB) reviews of FAA actions. Too often the NTSB rubber stamps a decision of the FAA, giving wide latitude to the FAA and making the appeals process meaningless.
ØAllows for federal district court review of appeals from the FAA, at the election of the appellant.
ØRequires the FAA undertake a Notice to Airmen (NOTAM) Improvement Program, requiring simplification and archival of NOTAMs in a central location. The process by which NOTAMs are provided by the FAA has long needed revision. This will ensure that the most relevant information reaches the pilot. Currently, FAA makes pilots responsible for knowledge of pre-flight conditions. Non-profit general aviation groups will make up an advisory panel.
ØMakes flight service station communications available to all airmen. Currently, the FAA contracts with Lockheed Martin to run its flight service stations. If a request is made for flight service station briefings or other flight service information under FOIA, it is denied to the requestor because Lockheed Martin is not the government, per se. However, they are performing an inherently governmental function and this information should be available to pilots who need it to defend themselves in an enforcement proceeding.
ØThe FAA’s medical certification process has long been known to present a multitude of problems for pilots seeking an airman certificate. The bill requires a review of the FAA’s medical certification process and forms, to provide greater clarity in the questions and reduce the instances of misinterpretation that have, in the past, lead to allegations of intentional falsification against pilots. Non-profit general aviation groups will make up an advisory panel.
The 59 cosponsors include: U.S. Sens. Daniel Akaka (D-Hawaii), Lamar Alexander (R-Tenn.), Kelly Ayotte (R-N.H.), John Barrasso (R-Wyo.), Mark Begich (D-Alaska), Roy Blunt (R-Mo.), John Boozman (R-Ark.), Richard Burr (R-N.C.), Thomas Carper (D-Del.), Saxby Chambliss (R-Ga.), Dan Coats (R-Ind.), Tom Coburn (R-Okla.), Thad Cochran (R- Miss.), Susan Collins (R-Maine), Bob Corker (R-Tenn.), John Cornyn (R-Texas), Mike Crapo (R-Idaho), Jim DeMint (R-S.C.), Michael Enzi (R-Wyo.), Kirsten Gillibrand (D-N.Y.), Lindsey Graham (R-S.C.), Chuck Grassley (R-Iowa), Kay Hagan (D-N.C.), Tom Harkin (D-Iowa), Orrin Hatch (R-Utah), Dean Heller (R-Nev.), John Hoeven (R-N.D.), Daniel Inouye (D-Hawaii), Johnny Isakson (R-Ga.), Mike Johanns (R-Neb.), Ron Johnson (R-Wis.), Mark Kirk (R-Ill.), Mary Landrieu (D - La.), Frank Lautenberg (D-N.J.), Mike Lee (R-Utah), Richard Lugar (R-Ind.), Joe Manchin (D- W. Va.), Jeff Merkley (D-Ore.), Jerry Moran (R-Kan.), Lisa Murkowski (R-Alaska), Bill Nelson (D-Fla.), Benjamin Nelson (D-Neb.), Rand Paul (R-Ky.), Rob Portman (R-Ohio), Mark Pryor (D-Ark.), James Risch (R-Idaho), Pat Roberts (R-Kan.), Marco Rubio (R-Fla.), Jeff Sessions (R-Ala.), Richard Shelby (R-Ala.), Olympia Snowe (R-Maine), Debbie Stabenow (D-Mich.), Jon Tester (D-Mont.), John Thune (R-S.D.), Pat Toomey (R-Pa.), Mark Udall (D-Colo.), David Vitter (R-La.), Mark Warner (D-Va.), and Roger Wicker (R-Miss.).

From http://inhofe.senate.gov/public/index.cfm?FuseAction=PressRoom.PressReleases&ContentRecord_id=b2ea5b7f-cd77-2082-66c1-575628f012e8
 
Is it just me or is the nitpick-enest "enforcement" ever?

.

Without knowing any details it's hard to call this an "enforcement". It very well maybe an "LOI" (Letter of Investigation) asking for information. Chances are there is more here than meets the eye.

If it is an LOI and this is the only issue, and the individual hasn't had other problems it will be taken care of through counseling or maybe a letter of warning.
 
The problem with these nit-picky regs IMHO is that folks will ignore them and it starts a culture of picking and choosing what regs to follow. My 2 cents.
 
As a side note, it appears your reference to the AIM is evidence the AIM is in fact regulatory. Some persons have debated that.:(
I don't think anyone will debate that the AIM tells you FAA-acceptable ways to comply with the regulations -- in fact, it says just that in the front of the AIM. Of course, there may be other ways to comply with the rules, but if you do what it says in the AIM, the FAA is pretty much bound to accept what you do as being legal. OTOH, if someone says "you can't do [whatever]," and the AIM says you can, then you can ignore what that someone says about doing [whatever].

So, in this case, since the FAA says in those AIM sections that those are acceptable ways to use your GPS under IFR despite an expired database, then you can legally do what it says in the AIM.
 
The problem with these nit-picky regs IMHO is that folks will ignore them and it starts a culture of picking and choosing what regs to follow. My 2 cents.

Exactly right. When an agency tries to enforce a rule they've consistently neglected, you have to wonder about the validity of the rule.
 
I heard that back in 1976 the FAR/AIM was only about an inch thick. I'm guessing that in a few years, it will be comprised of several volumes, much like those old sets of encyclopedias we used to buy from the door to door salesmen on easy monthly payments.

John
 
Exactly right. When an agency tries to enforce a rule they've consistently neglected, you have to wonder about the validity of the rule.

So, you would support the quartering of soldiers in your home now? That particular rule hasn't been enforced for oh...a couple centuries, yet do you think you would have the right to enforce it as a valid rule today?
 
I can guarantee that you have broken several tax laws in the last 5 years -- just like every other citizen -- unless you have an active IRS Tax attorney and accountant on retainer.
I do, and have done so for more than 20 years. I took a bunch of accounting courses in college and grad school, and I learned enough to know when my finances passed my own ability to do my own taxes. Whether it's right or wrong that the tax system is so complex that someone who did most of an MBA before switching to Aviation Management can't do his own taxes is not germane to that issue. Likewise, whether I like this particular FAR or not isn't germane to my teaching or complying with it.

My advice to any owner I fly with is "Log anything you do to this airplane -- you can't be faulted for over-compliance." I do the same.
Then I guess you do teach your trainees the rule about logging GPS updates and how to comply with it, even if you don't like the rule.
 
I do, and have done so for more than 20 years. I took a bunch of accounting courses in college and grad school, and I learned enough to know when my finances passed my own ability to do my own taxes. Whether it's right or wrong that the tax system is so complex that someone who did most of an MBA before switching to Aviation Management can't do his own taxes is not germane to that issue.

Sure it is -- the tax code is yet another example of overly complex creations of massive bureaucracies. IRS employees provide different answers to various tax problems, and it's no different with the FAA.
 
Then I guess you do teach your trainees the rule about logging GPS updates and how to comply with it, even if you don't like the rule.

It's not a matter of "like/dislike." That's mere fancy.

I question the rule's purpose. That's the realm of reason.

A logbook entry for each VFR DB update is pointless. Consider this: If you never updated the DB would you be legal to fly VFR?
 
It's not a matter of "like/dislike." That's mere fancy.

I question the rule's purpose. That's the realm of reason.

A logbook entry for each VFR DB update is pointless. Consider this: If you never updated the DB would you be legal to fly VFR?

Dan,

The rule isn't to log database updates. The rule is to log preventive maintenance. The requirement to log preventive maintenance was added in 1982. The FAA noted that the logging requirement would take at most a few minutes and as evidence that the financial impact was minor they cited that there were no comments from the public on the logging requirement in the NPRM. At the time, database updates weren't in use and later when they were initially added, the task of updating the database was considered maintenance, not allowed to be performed by the pilot and you had to pay the avionics shop to do it. In 1996, the list of approved preventive maintenance items was expanded to permit the updating of databases by the pilot.

This is one of those items that many pilots make an enormous deal over a task that truly takes less than the time to complain about it. I personally use a form that has all the boiler plate of the log entry and I just fill in the blanks for the date, effective date of the database, and my signature. For me, it takes about 10 seconds. Now that I think about it, that has cost me a minute in the last year.:mad2:
 
I keep mine on a piece of paper that I keep in the glove box. I would not share the record at the time of a ramp inspection and the inspector has no authority to look at it at that point in time or enter my aircraft. The inspector may request I produce the log record at a mutually acceptable point in time in the future.

If you have it why would you not show it to the inspector? If by doing so you satisfy his curiosity and end the ramp check that would seem a wiser course of action than dragging it out for yet another meeting.

As a disclaimer I have never been ramp checked but if I ever do get one I plan to cooperate as I will have checked everything required by regulation prior to the flight and have nothing to hide.

Rich
 
If you have it why would you not show it to the inspector? If by doing so you satisfy his curiosity and end the ramp check that would seem a wiser course of action than dragging it out for yet another meeting.

As a disclaimer I have never been ramp checked but if I ever do get one I plan to cooperate as I will have checked everything required by regulation prior to the flight and have nothing to hide.

Rich

This is not aimed at Mr. Collins.

Too often people will follow the advice of "Internet experts" and wind up digging a deeper hole than intended.

Cooperation and a good attitude go a long way in making something routine as a ramp inspection quick and painless.
 
Dan,

The rule isn't to log database updates. The rule is to log preventive maintenance. The requirement to log preventive maintenance was added in 1982. The FAA noted that the logging requirement would take at most a few minutes and as evidence that the financial impact was minor they cited that there were no comments from the public on the logging requirement in the NPRM. At the time, database updates weren't in use and later when they were initially added, the task of updating the database was considered maintenance, not allowed to be performed by the pilot and you had to pay the avionics shop to do it. In 1996, the list of approved preventive maintenance items was expanded to permit the updating of databases by the pilot.

This is one of those items that many pilots make an enormous deal over a task that truly takes less than the time to complain about it. I personally use a form that has all the boiler plate of the log entry and I just fill in the blanks for the date, effective date of the database, and my signature. For me, it takes about 10 seconds. Now that I think about it, that has cost me a minute in the last year.:mad2:


I do the same. Anytime I grab a wrench or safety wire I put a simple entry in a log.

However, I don't log every fuel sample, every oil check, every unbuttoning of the cowl, every tire pressure check, and every push into the hangar. I also don't log every recharge of my 12v SLA battery that powers my Sporty's SP-200 handheld transceiver. I don't log turning the radio on or off.

In other airplanes I have flown, I logged VOR checks, Tach time each day, and 430W updates.

I'm not questioning the propriety of logging. I'm questioning the rule that a VFR GPS database update must be logged.

It's pointless -- the VFR GPS screen could display Looney Tunes -- who cares? It's Visual Flight Rules.
 
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