No longer need to log GPS updates?

timwinters

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I haven't seen this discussed here...it has been over at CPS...pardon me if I missed it here...

It appears that, effective January 29th, one will no longer need to log avionics database updates as it is no longer considered maintenance.

SMASH HERE FOR REVISED CFR
 
It is important to note that this change only applies to GPSs that can be updated with a plug-in cable or a removable media card. For example, there are some GPS units where you have to slide out the GPS from the tray and pull/change the cartridge from the back of the unit. This is not included in the new rule and still must be done the old way.

The KLN89B, for example, has a removable card or you can plug a cable into a jack on the panel and load the data. Either of these methods fall under the new rule and may be done by the operator and without a logbook entry.

That said, I've been swapping cards for several years and never logged it once. Even on FAA checkrides, the examiner occasionally has asked if the database is current, but never asked to see it logged anywhere.
 
..... Even on FAA checkrides, the examiner occasionally has asked if the database is current, but never asked to see it logged anywhere.

I bet, since on initial start up of the device, the latest revision is on the first screen that pops up..:yes:
 
I can log the VOR checks in both the SL30 and the GNS480. I can't say I've ever heard of anybody being ramped for a VOR check but boy when I did my checkride, I made sure th SL30 which flashes the "LAST VOR CHECK" date at power up had the info on a current one.
 
It is important to note that this change only applies to GPSs that can be updated with a plug-in cable or a removable media card.
Half true. Read the preamble to the regulation. If you have to hook a laptop to the unit via that cable, the new exception does not apply, and it is still maintenance requiring a log entry. Further, by removing it from preventive maintenance, it will take an Airframe mechanic to do that. Bad news for those with King GPS's.
 
I can log the VOR checks in both the SL30 and the GNS480. I can't say I've ever heard of anybody being ramped for a VOR check but boy when I did my checkride, I made sure th SL30 which flashes the "LAST VOR CHECK" date at power up had the info on a current one.
Did you add your signature with a Sharpie on the LCD? At one point I was tempted to put a sticker on the panel with my signature and a note that said I made the last DB update on the date indicated by the GNS480 but I never got a "round tuit".
 
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Half true. Read the preamble to the regulation. If you have to hook a laptop to the unit via that cable, the new exception does not apply, and it is still maintenance requiring a log entry. Further, by removing it from preventive maintenance, it will take an Airframe mechanic to do that. Bad news for those with King GPS's.
Are you certain about that. I don't see anything suggesting this unless you consider a laptop and cable to be "special equipment" and lacking a specific definition of that I'd opine that they are not. I also pretty clearly recall this being a discussion point in a NPRM response by the FAA where they indicated that using a laptop and cable was something a pilot could do.
 
Are you certain about that. I don't see anything suggesting this unless you consider a laptop and cable to be "special equipment" and lacking a specific definition of that I'd opine that they are not. I also pretty clearly recall this being a discussion point in a NPRM response by the FAA where they indicated that using a laptop and cable was something a pilot could do.
Read the preamble. It's there.
 
The preamble does say if a laptop/dataloader is REQUIRED... So if youre just hooking the laptop up out of convenience rather than load the data onto a datacard, it looks like you're good. If the only way to upload is to do it via cable then it looks like a log entry is required.
 
The preamble does say if a laptop/dataloader is REQUIRED... So if youre just hooking the laptop up out of convenience rather than load the data onto a datacard, it looks like you're good. If the only way to upload is to do it via cable then it looks like a log entry is required.

That's what I read too.
If you can install a new SD card you are good.
If you can up date that SD card by removing it, putting it in your laptop and then put the updated card back in the GPS unit, you are good to go.

If you have to connect your "data transfer unit/laptop" to the unit with a cable, you are not good to go.
 
There's a long thread on the red board about this. The new rule is great for some pilots, but really bad for others. Unintended consequences it would seem.
 
Read the preamble. It's there.
I don't believe a serial cable is a "dataloader". A dataloader is a piece of electronic gear that costs many thousands of dollars and is used to update the DB in the FMS of a transport category aircraft.
 
The preamble does say if a laptop/dataloader is REQUIRED... So if youre just hooking the laptop up out of convenience rather than load the data onto a datacard, it looks like you're good. If the only way to upload is to do it via cable then it looks like a log entry is required.
I think that interpretation is wishful thinking. Someone is going to have to get the FAA to say for sure.
 
I don't believe a serial cable is a "dataloader". A dataloader is a piece of electronic gear that costs many thousands of dollars and is used to update the DB in the FMS of a transport category aircraft.
They came out and said "laptop." I think that means a laptop, but I could be wrong.
 
Half true. Read the preamble to the regulation. If you have to hook a laptop to the unit via that cable, the new exception does not apply, and it is still maintenance requiring a log entry.

I'm not seeing that.
 
The Background section of the document I read does indeed exclude laptops as Ron says.

The excerpt is below. Ron seems to be focusing on the 2nd paragraph below which does indeed exclude laptops, but I think the preceding lines give the context for this exclusion as "large transport category aircraft." So I don't think the laptop rule was intended to be applied to small GA planes -- but it's not very clear.


Pilots will not be
permitted to update databases of
installed avionics that use portable
dataloaders such as those used with the
older navigational systems installed on
large transport category aircraft.

We have extended the rule to allow
all certificated data-transfer
mechanisms, but we specifically
exclude means of data transfer that
require physical connection to installed
equipment such as portable dataloaders
and laptops

The rule itself is written simply, and doesn't mention laptops. Just tools and special equipment:

Updates of databases in installed
avionics meeting the conditions of this
paragraph are not considered
maintenance and may be performed by
pilots provided:
(1) The database upload is:
(i) Initiated from the flight deck;
(ii) Performed without disassembling
the avionics unit; and
(iii) Performed without the use of
tools and/or special equipment.
 
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The Background section of the document I read does indeed exclude laptops as Ron says.

The excerpt is below. Ron seems to be focusing on the 2nd paragraph below which does indeed exclude laptops, but I think the preceding lines give the context for this exclusion as "large transport category aircraft." So I don't think the laptop rule was intended to be applied to small GA planes -- but it's not very clear.
Right -- unintended consequences. Wouldn't be the first time. My personal guess is whoever wrote that thought everyone has a Garmin and just didn't know about the King KLN's. I think the FAA needs to set this straight, and I'm trying to get them to do that.
 
The Background section of the document I read does indeed exclude laptops as Ron says.

The excerpt is below. Ron seems to be focusing on the 2nd paragraph below which does indeed exclude laptops, but I think the preceding lines give the context for this exclusion as "large transport category aircraft." So I don't think the laptop rule was intended to be applied to small GA planes -- but it's not very clear.

That paragraph is not part of the rule.
 
That paragraph is not part of the rule.
While that is true, it is also true that when issuing an interpretation the Chief Counsel looks to the discussion in the NPRM and/or Final Rule to determine the intent, much as the Supreme Court looks to the Congressional Record for the discussion of the legislators in enacting legislation. Point is that it can be read several ways, and there is no solid reason to believe that if it comes down to it, it won't be read per the cited discussion rather than what some here hope it means. That is why I urge caution before you throw away your little GPS logbook -- and it's really not that much of a burden to keep doing it that way until you're sure of the situation.
 
They came out and said "laptop." I think that means a laptop, but I could be wrong.
I think they also said "and dataloader" but I don't have the whole thing with preamble to read so I'm working from memory here.
 
I have a KLN-89, and I'm not going to log updates any more. If I'm ever questioned about it I'll just point to the black letters of the regulation.

The discussion isn't part of the regulation.
 
I have a KLN-89, and I'm not going to log updates any more. If I'm ever questioned about it I'll just point to the black letters of the regulation.

The discussion isn't part of the regulation.
You are free to go by your own personal interpretation of that regulation (and any other, for that matter). However, the FAA will go by its own interpretation, and generally speaking, the discussion in the NPRM/FR is the first place the Chief Consel looks when interpreting a new regulation like this. Caveat aviator.
 
You are free to go by your own personal interpretation of that regulation (and any other, for that matter). However, the FAA will go by its own interpretation, and generally speaking, the discussion in the NPRM/FR is the first place the Chief Consel looks when interpreting a new regulation like this. Caveat aviator.

OK, I'm reading the FR notice, and I see nothing like what you're claiming.

Basically, this rule is more geared towards letting 121/135 pilots update databases in the field.

For example, from the FR:
C. Who is affected by this rule?
This rule affects all operators of
certificated aircraft equipped with
installed avionics that: (1) Have a pilot
accessible data transfer mechanism
permanently installed on the flight
deck;
(2) can be updated without the use
of tools, and (3) is programmed to
provide a data load status. This rule will
also affect maintenance personnel and
repair stations that parts 121, 129, and
135 operators were previously required
to pay for updating databases.

A port in the cockpit to plug into to upload a database certainly qualifies as a "pilot accessible data transfer mechanism permanently installed on the flight deck".
 
Half true. Read the preamble to the regulation. If you have to hook a laptop to the unit via that cable, the new exception does not apply, and it is still maintenance requiring a log entry. Further, by removing it from preventive maintenance, it will take an Airframe mechanic to do that. Bad news for those with King GPS's.

It also doesn't change the list of "maintenance" items at all, only provides an exception to those requirements. If the cable is considered to be "special equipment", the exception does not apply, and it reverts to preventative maintenance that can be conducted, under part 91 operations, by a pilot.
 
It also doesn't change the list of "maintenance" items at all, only provides an exception to those requirements. If the cable is considered to be "special equipment", the exception does not apply, and it reverts to preventative maintenance that can be conducted, under part 91 operations, by a pilot.

But would still need to be logged in a logbook.
 
But would still need to be logged in a logbook.

IF, and this is a big IF, that cable is considered "special equipment".

Ron was saying that this removed GPS updates from preventative mx, which would mean you'd need an A&P to do it if that cable was considered special equipment.

I'm also not seeing the obvious language he refers to in the preamble of the regulation that such a cable would be "special equipment". My reading of the preamble is that the intent is to permit pilots to do updates so long as they follow manufacturer's recommended procedures and don't have to go ripping stuff out of the panel to accomplish the update.
 
IF, and this is a big IF, that cable is considered "special equipment".

Ron was saying that this removed GPS updates from preventative mx, which would mean you'd need an A&P to do it if that cable was considered special equipment.

I'm also not seeing the obvious language he refers to in the preamble of the regulation that such a cable would be "special equipment". My reading of the preamble is that the intent is to permit pilots to do updates so long as they follow manufacturer's recommended procedures and don't have to go ripping stuff out of the panel to accomplish the update.

Oh, I'm with you, but I don't think either of us have an oak tree growing out of our posterior regarding regulations.
 
huh, who knew?

Why is it that I could write a clear, concise and unambiguous "rule" for something as petty and idiotic as this before I brush my teeth in the morning. Yet a huge bureaucracy, fact finding committees, public panels,NPRMs etc... can't do the same? It almost seems like they're just @#$%^ing with us...like we're the victim of a cruel FAA office bet.... Or at least the folks who get wound up about this stuff are.
 
huh, who knew?

Why is it that I could write a clear, concise and unambiguous "rule" for something as petty and idiotic as this before I brush my teeth in the morning. Yet a huge bureaucracy, fact finding committees, public panels,NPRMs etc... can't do the same? It almost seems like they're just @#$%^ing with us...like we're the victim of a cruel FAA office bet.... Or at least the folks who get wound up about this stuff are.

They purposely make ALL rules vague so they have something to do next year... it's called "job security" :yes::yes:..

And they insult our intelligence thinking we don't see it..:mad::mad2::mad::mad2:
 
Does this apply to VFR pilots too? I have a Garmin 496 and a Garmin 530w. Neither one has been updated in about a year, and I don't have logs for either of them. And my (VFR) flight review is coming up. Do I need to update my GPS databases? It sounds like I won't have to log it at any rate.
J
 
Does this apply to VFR pilots too? I have a Garmin 496 and a Garmin 530w. Neither one has been updated in about a year, and I don't have logs for either of them. And my (VFR) flight review is coming up. Do I need to update my GPS databases? It sounds like I won't have to log it at any rate.
J
There is no FAA requirement to update a database in any GPS not used for IFR navigation. However, if you do update the database in a installed GPS, you must comply with the regulations on updating. What you do with a non-installed GPS is your own business as long as you don't try to use it for IFR navigation, which is prohibited regardless of database currency.
 
Read what NoHeat quoted above in post 16.

Even with that, they still remain in the Preventative Mx section, unless covered by the new exception. So, if they're not covered by the exception, the remain Preventative MX...I see nowhere that it says these things require any A&P intervention.

Please quote from the FR where you see this.
 
Even with that, they still remain in the Preventative Mx section, unless covered by the new exception. So, if they're not covered by the exception, the remain Preventative MX...I see nowhere that it says these things require any A&P intervention.

Please quote from the FR where you see this.
You've lost me.
 
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