What About Portable GPS?
I was flying along the other day when the controller called a Bonanza pilot on the frequency. “I see that you have filed a slant uniform but do you have some sort of GPS or something you could use to fly direct to XYZ?” the controller asked.
The controller had acknowledged that the Bonanza did not have an IFR approved RNAV system onboard or the pilot would not have filed slant uniform as the equipment suffix. But the controller, trying to be helpful, was dropping the biggest hint that it would be okay for the Bonanza pilot to accept a direct en route clearance if he had some sort of navigator.
I was hoping the Bonanza pilot would understand the situation, say thanks, and head off direct to his destination. But instead he launched into a long description of the portable navigation system—complete with detailed moving map display—he had in the cockpit.
The controller tired again by repeating the clearance offer of direct to the destination. But the pilot of the Bonanza declined saying “my portable system is not IFR approved.”
By now I’m sure the controller was chomping big chunks out of his tongue as he told the Bonanza pilot to “fly heading 000 until receiving XYZ.”
What we had were two people trying their best to be helpful. The controller wanted to help the Bonanza pilot shave a few miles off of his trip, and the Bonanza pilot was determined to remain within the regulations as he understood them.
The reality is that controllers know pilots are flying around with all sorts of portable navigation devices, many of them with accuracy and capability equal to, or even beyond certified systems. Portable systems can show satellite weather, moving maps with all airway, VOR and airport information, and some even have terrain warning built in. There are mounting devices for the popular portable systems that allow a pilot to “plug them in” so they function very much like avionics that are permanently installed.
For en route navigation portable GPS systems provide all the accuracy, precision and reliability that we need, and controllers know it. That’s why they routinely offer direct clearances even if the equipment suffix letter the pilot filed with his flight plan does not show RNAV capability.
For controllers issuing a direct clearance to an airplane in radar contact is really the same as issuing a heading to fly. That’s why you’ll often have a controller ask you for the heading to your destination, or to another point along your route. You read back the heading from your navigator—certified or otherwise—and he clears you to fly that heading. Everybody is happy and no rules are broken or even bent.
Using a non-approved navigation system to fly an IFR approach is another matter, even though many portable GPS units store approach procedures, and even approach charts, in their data bases. An instrument approach takes us close to terrain and obstructions and the precision of a navigation system needs to have been demonstrated before relying on it to miss the ground by only a few hundred feet.
Navigating en route where terrain clearance at approved altitudes is large has none of the risks of flying an approach. And en route separation for airplanes flying direct is provided by radar, not precise flying of a published route so small deviations from a true direct path do not compromise lateral separation.
Pilots, like the one I overheard in the Bonanza, are worried that somebody is going to bust them for accepting a direct en route clearance while using an unapproved navigator.. They shouldn’t. The controllers know how things work, they’re not out to get us, they just want to be helpful and keep traffic flowing smoothly.
The only rule the Bonanza pilot could have broken in this situation is to have filed an equipment suffix indicating that he had approved equipment that wasn’t there. That is a particularly grievous offense when it comes to RVSM, and the FAA has cracked down on pilots who either indicate they have RVSM certification on their flight plan, or accept a clearance into RVSM airspace without having the certification and without telling the controller.
Unlike a direct clearance that involves wide lateral separation from other IFR aircraft, flying in RVSM airspace offers only 1,000 foot vertical separation, and that’s not much room for error at high altitudes where altimeter errors in non-approved systems are more likely.
An important issue for FltPlan.com users is to go into your aircraft profile and update the equipment list if something changes, particularly if your approval for RVSM changes. If you don’t keep your aircraft profile up to date you could be telling the FAA lies that it really does care about. It’s best to enter the correct equipment using the “A/C ICAO DATA” button that is on the bottom left side of the FltPlan.com main menu screen. Simply click on every type of approved equipment you have onboard and FltPlan.com will automatically translate that to the proper ICAO equipment designations to file each time with your flight plan.
If you have been accurate in filing your flight plan and the controller offers a direct en route clearance, take it.
Generally, I agree that a pilot with a VFR Only GPS should be allowed to fly via that device as long as both the controller and pilot understand that it is NOT a certified device and they both accept the risks that are inherent in its use. And I myself has been in the same situation and used a VFR GPS for a direct.
However, I can also understand a pilots resistance to using one. You didn’t mention the conditions or where the event took place, so this might not apply. For me, personally, I would have to consider the conditions of the flight as to whether or not I’d accept such an instruction/clearance*. For instance, I personally would not accept such a clearance if I was flying IMC, nor would I at night over mountainous terrain. In my opinion, in those situations I would rather have the little extra peace of mind that a certified unit has with an unambiguous understanding between myself and ATC.
While people on either side of the microphone understood each other when the clearance was issued, that does not necessarily mean that that same understanding will be passed on to any new controller. It would be a sad day if separation was lost because (as unlikely as it may be) a VFR GPS failed to report a loss of signal and a pilot strayed from his course. In the worst case scenario, while it might ultimately be determined that the controller was completely at fault, the pilot might not still be alive to hear.
* As a side note, I hate to call this a clearance, I’d have to go to the regs, but if a controller says “cleared direct…” can a pilot accept a “clearance” when they can’t technically comply with all the regulations of flying that clearance? I know I’m splitting hairs here, just food for thought.
Mac –
While I fully concur with your thought process, most GA pilots using portable avionics are pushing the regulatory envelope, often blindly so.
At a time when technology is enabling highly reliable portables, and the market is ripe with low-end TAWS, CDTI, Weather, SynVis, etc. … manufacturers and pilots alike are flying into a regulatory Bermuda Triangle.
Not to be overbearing with a walk through 14 CFR and other FAA rules … perhaps just a example of the conundrum that GA is facing.
Even if we assume that everyone with a 496, AV8OR, or similar system has completed the AC 91.21-1B requirements for use of a PED in their aircraft … what is the GA community doing to prevent these safety-enabling systems from falling under the broad regulatory umbrella of the evolving EFB guidance in Draft AC 120-76B?
Together, those two AC’s allow Non-EFB PEDs only during cruise, or climbs/descents above 10,000 feet AGL. For a GA pilot to operate a 496 during non-cruise segments below 10,000 feet, the system must be approved as an EFB PED.
But … depicting ownship position, let alone CDTI or other safety information, on an EFB PED requires a Class 3 system running Type C applications with accompanying FAA 8900.1 based approvals. Ouch.
With AirVenture upon us, are the manufacturers and vendors who line the pavilions risking legal jeopardy if the NTSB finds portable avionics as a causal factor in a GA accident?
Is the FAA risking legal jeopardy for ignoring the portable avionics issue for so long, and likely to abate those risk through onerous regulations?
So, we are all on board with the premise that using these highly capable portable systems make sense for even the casual GA pilot.
Now how as a community do we impart sanity at the FAA to both prevent risk suppressing regulations, and also keep us out of that “standby to copy down a number” minefield ?
JP
In general, it is really pointless not to accept the offer of ATC to go direct if you really can. You have to use your own judgment. This business of what is and isn’t technically legal can be way overblown. The first question is if it is safe or not. There are a surprising number of things in aviation that, while legal, are not safe, and vice versa. Many years ago an instructor who was about the “straightest arrow” I’ve ever come across in aviation told me if you look hard enough you can find something illegal on every flight!
You mean I don’t have to pay for expert adcvie like this anymore?!
Very interesting. Someone actually typing and posting advice on using portable GPS systems in the IFR environment with a non-IFR certified device. Next you are going to advise the database does not have to be up to date and it is ok to use the 496 or similar system with NEXRAD to pick you way around thunderstorms too. It is so much better and more accurate than an expensive IFR device.
Remind me not to be anywhere near you in my aircraft while you are flying IFR on your VFR device. If the controller would then need you to go to an intersection, that is OK too? What happens if the intersection was moved slightly? That is a dangerous game a pilot starts to play when he starts following only the regulations that he feels are good, correct or necessary.
Bad advice Mac! What other regulations are unnecessary? Safety really is highly over rated isn’t it?
My brother suggested I might like this blog. He was totally right. This post actually made my day. You can not imagine just how much time I had spent for this information! Thanks!