Foreflight Legal for IFR Navigation?

[M016576]

http://www.faa.gov/news/safety_briefing/2010/media/JanFeb2010.pdf

boom.

RAIM for non-WAAS.  No RAIM required for WAAS.... unless there's a WAAS outage... then back to RAIM....

 

[3914N]

14 minutes ago, M016576 said:

You soldered together a stratux?  Why? 

Just buy the raspberry pi and stick the USB ADSB receiver and gps puck in.  No need to solder anything: it's a very easy "build."

not saying its better than a 430- but the only tools required to "build" a stratux are your two hands.

I built mine about a year ago before Foreflight dropped "support" for the AHRS features on the GPS puck.  At that point, it was required to connect the puck using the header pins to get the IMU data.

Now that the AHRS feature has basically been scrapped, you are correct in that the USB connection is a better way to go.

[MB65E]

Mike- I guess the real question is where's lunch at?

However, I haven't read the last FAA memo that was just posted yet. 

-Matt

[midlifeflyer]

4 hours ago, 201er said:

I think that AC settles that matter quite well. The only question then is, are you sure there isn't some new AC or LOI that supersedes allowing for portables recently?

Also, how do users of non-certified GPS get away with filing "VFR gps" in remarks and getting direct routes? Is this a loophole, ATC turning a blind eye, or downright allowed by some other reg?

It's a hint-hint-wink-wink loophole that was used far more when panel GPS was not as prevalent. In order for ATC to issue an off airway route, you have to be in radar contact. So early on, the long version of the conversation took the form of looking like a pseudo radar vector.

Typing this gave me a sense of deja vu. So I checked. Here's a longer post I did on the subject in a thread here in 2014. 

BTW, the requirement for certified GPS is tied to the "equipment suitable" part of 91.205 via the Part 1 definition of "suitable RNAV system in 1.1 which, cleverly enough, incorporates guidance material like ACs and the AIM. No, don't expect the FAA to forego the requirements that equipment be certified, installed and tested to FAA spec before being officially used for primary IFR navigation in favor of an off-the-shelf consumer product any time soon, no matter how good.

 

[RLCarter]

I was told by a DPE when I was taking my Instrument check ride that the iPad is legal for enroute navigation in both VFR & IFR, it is not legal for the approach except for displaying the approach plate. After the check ride he pulled out AC-120-76 (I believe), I didn't read it he just pointed and said here it is.... I also attended a FAAST seminar on ADS-B where the FAA rep said that the GPS unit in the iPad is the same unit that is used in one of the major avionics manufacturers. 

[midlifeflyer]

4 hours ago, Piloto said:

It is impossible for Foreflight to get a TSO or FAA approval because Foreflight is an application than can run on multiple non FAA approved devices. Tablets and cell phones have no FAA approval. The host device operating system and Foreflight has to prove that it complies with DO-178B. https://en.wikipedia.org/wiki/DO-178B. Only the device manufacturer can prove compliance. And I don't think that Apple or Samsung would be willing to spend any money to get FAA approval.

José

Not for TSO type stuff but, technically, ForeFlight does have "FAA approval" for other things. Although we vanilla Part 91 folks can use EFBs pretty much reg-free, more highly regulated operators need approval under the guidelines in AC 120-76c.  ForeFlight is one of a few apps that have received approval. The airlines are, of course, mostly using Jepp apps but ForeFlight has been approved for a number of 132, 135, and other regulated ops. The even have a function set up to provide some of the approval documentation. https://www.foreflight.com/campaigns/electronic-flight-bag-approval/

 

[midlifeflyer]

16 minutes ago, RLCarter said:

I was told by a DPE when I was taking my Instrument check ride that the iPad is legal for enroute navigation in both VFR & IFR

He misspoke or you misunderstood. There's a required and sometimes difficult  distinction that needs to be understood.

yes, it is "legal for VFR navigation" because there is no primary navigation equipment required for VFR navigation. 

It is also "legal for IFR navigation" in exactly the same way a paper en route chart or a wristwatch or E6B fir that matter is legal for IFR navigation. As a chart. For general situational awareness. To time your route. But not as the primary navigation source. That's for approaches as well as en route.

The conceptual distinction is whether you are permitted to use it to assist with situational awareness for navigation on the one hand or as a "primary source" for IFR navigation on  the other.

The two ACs on the subject are 120-76c for regulated operators and 91-78 for us little GA guys.

[wrench]

201er, I have had two on-board portables a (Garmin 196 and Skymap) GPS's lose satellite signal at the same time when using old Narco NAV/COM's tuned to certain VOR frequencies in a PA-28-180 Challenger on a VFR trip from Florida to Michigan. Failure was verified afterwards by a local avionics tech at my home field. Be careful if he wins the bet, fly to lunch in your plane if it looks like it could be IFR. 

[Bob_Belville]

7 hours ago, 201er said:

And yet VOR/NDB are still regarded as robust systems. Unusable radials, drift, calibration errors, other issues that are beyond my level of sophistication... the cheapest of the cheap gps systems still seems to be more robust, accurate, and reliable, wouldn't you say? Why is it ok to fly an NDB or timed VOR approach but not use some sort of portable gps?

At one time the NDB 3 approach was the only instrument approach at KMRN, my home drone and I flew it many times. But the mda was a couple of hundred feet higher than the RNAV (GPS) approaches that we now enjoy. The difference was not arbitrary, it reflects the (lack of) precision inherent with the ADF. To be able to descend to 250' AGL requires proper equipment.    

[Mooneymite]

Perhaps the dark side of the OP is that we may be sharing IFR airspace with aircraft not legally equipped.

Our IFR protections assume everyone is adhering to the standards.

How many other knuckleheads are there out there betting a lunch and our lives that portable equipment is good enough?  

[peevee]

So... you could in theory use your stratus/ipad/whatever to "navigate" enroute by asking for direct wherever you're going and asking for an assigned heading to get there as a /a or whatever you non /g people file.

[Cruiser]

Why would the FAA approve software that they have not fully tested? The FAA has NO control over revisions and updates. Any change to certified GPS programs (Garmin, Avidyne, Collins, BK etc) must be re-submitted to the FAA for approval and testing before it gets approved. Look how long Avidyne has been waiting to release version 10.2

The FAA has no control over the portable stuff. They will never be approved for certified use.

[Marauder]

I think what people are getting hung up on is the legality of using the geo-referenced feature of these apps. The EFB policy was intended to address the usage of electronic charts in place of paper. The "bells and whistles" features of these apps are just that. The EFB circular never authorized the electronic versions to function as a navigation device.


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[BradB]

Before I bought my plane, I was flying a variety of rental death traps.  One was an archer without a gps.   I had filed IFR along airways, including transiting a bravo airspace.  Weather was VFR. Distance 160+ nm. In radar contact. 

Departure controller: do you have a handheld GPS?

Me: Yes. 

Deparure Controller: You can proceed direct destination.

 

This was also the same Bravo airspace that I was cleared to transit with a non-functioning transponder without any hassle on a different occasion.  Rentals....

 

disclosure:  don't want to get anyone in trouble over this. Maybe it was all just a dream.  

 

Brad. 

[gsengle]

No they do that. They basically gave you a vector and know you'll be on radar... it's a little shady but doesn't mean handheld is IFR approved...


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[Marauder]

I think in the early days of GPS, when there were no panel mounted solutions, I think everyone was still learning about the new technology. I remember there was a big fear that because it was a "military" system, that during times of war they would shut it off. Never happened.

Before I upgraded to a /G, I would still get the direct routing with the "VFR GPS Equipped" in the comments section of an IFR flight plan. It only happened as gsengle states, when in radar coverage. I never got a "direct destination" though, only some way out VOR that I could never receive with the Nav radio. 

[gsengle]

And of course now we all have to use ICAO codes now, bye bye /G

 

Greg

 

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[Vance Harral]

Couple of comments to add.

First, I think it's important to point out that what's ultimately certified in the certification process is an "installation", not just a "device".  I don't know what manufacturer's GPS receiver is installed in a iPad, but let's assume it's the same one in a GTN650 (doubt it, given that that the integrated circuit in the iPad is a combination GPS receiver and 4G integrated circuit, but that's not really germane...)  Even if we set aside the difference in software that talks to the GPS receiver, the receiver's behavior and performance depends on the GPS antenna being used and the connection to it, among other things.  Panel-mount GPS hardware is connected to an external GPS antenna mounted on the roof of the airplane for best reception, and that entire installation is addressed by the certification process.  The iPad's antenna is inside the cabin near a bunch of other RF devices, potentially changing every time you move the iPad.  That doesn't mean the iPad doesn't work well, but there's a reason why different pilots in different airplanes have different experiences with reception on portable devices.  As another example, I fly with a Stratux portable ADS-B in setup.  It works great, but only if I hold the antennas up to cabin window, and move them around depending on where I am.  That's not something any reasonable person would "certify".

On the other hand, it's important to understand the certification process isn't the gold standard most certification advocates imagine it to be.  I have a relative in the certified avionics software business, and when he tells me how the boxes are verified vs. the way I do things in the microprocessor design world, it makes me uneasy.  Here's just one of several cringe-worthy stories I've heard from him:

[my relative]: I opened a bug because if you press button A followed by button G followed by button C, the whole box locks up and must be power cycled.

[responder]: Bug closed, that's an invalid key sequence.

[my relative]: Bug re-opened.  It's never OK for the box to lock up, regardless of whether the key sequence is "valid".

[responder]: Bug closed, no pilot would ever do that.

[my relative]: Bug re-opened.  You're not a pilot, are you?  Ever flown in turbulence, accidentally hit the wrong key?

[responder]: Bug closed, that's just not part of our certified test sequence.

[my relative]: Sigh.  I give up.

[DER]: I see you've closed all open bugs, looks good for certification sign-off!

Even from a single manufacturer specifically in the aviation business, there are holes in both certified and uncertified flows.  Shortly after acquiring a Garmin GPSMAP396, I found a bug in the way the HSI behaves when turning away from the FAF on an approach, as one might do entering a hold or procedure turn.  I reported the bug to Garmin and they confirmed the bad behavior.  But it was never fixed, and their final response was essentially, "Yeah, it doesn't work the way we meant it to, but you're not really supposed to be using it for reference on approaches even though the software gives FAF-to-MAP guidance".  Later, we put a GTN 650 in the airplane, and subsequently received notice of a bug wherin if you configure it with a user-defined field that is a shortcut to a checklist, it can "brick" the unit, requiring a visit to the avionics shop to fix it (see Garmin Service advisory SA1503).  You'd think the certification process would have caught this, but nope.  No guarantees either way.

Edited March 2, 2017 by Vance Harral

[midlifeflyer]

4 hours ago, Marauder said:

I think what people are getting hung up on is the legality of using the geo-referenced feature of these apps. The EFB policy was intended to address the usage of electronic charts in place of paper. The "bells and whistles" features of these apps are just that. The EFB circular never authorized the electronic versions to function as a navigation device.
 

Maybe. But the direct-but-not-/G game was going on long before the 1st iPad appeared with (or even without) real aviation maps and charts. People were using this to go "direct" 20 years ago.

Personally, I was using one of these to go "IFR direct" when I had a loss of power and an emergency. Never even part of the equation.

[carusoam]

I prefer the factory built airplane for the same reason I prefer the factory built nav devices...

I don't like to be the first person to find something is wrong with my equipment or its installation.

Portable devices have a tendency to run out of power or have their antennae compromised, or succumb to radio interference by old installed radios set to particular frequencies.

just because it looks the same, doesn't mean that it is the same... if it works today, in this part of the country... will it work tomorrow in a different part of the country..?

As far as navigating with an iPad...  how often does it overheat in the cockpit when the sun shines on it?

How often does it lose satellite signal when being held low out of the sun?

Legal or not legal, good argument sort of.

Good idea or not a good idea, this is just a way to get an able pilot into some tough challenges.

How would the FAA know you are flying with portable equipment....? The moment it overheats and goes black or loses its signal, it will take several minutes of flying and ATC will be asking some tough questions.

The portable devices add some great skills to the cockpit.  They just stink when it comes to reliability as primary nav devices.

Sounds like a goofy argument at best.

Best regards,

-a-

 

Edited March 2, 2017 by carusoam

[cnoe]

9 minutes ago, carusoam said:

As far as navigating with an iPad...  how often does it overheat in the cockpit when the sun shines on it?

I LOVE my iPad/Stratus combo and geo-referenced plates BUT...

Just this past weekend my Air2 shut down mid-flight due to temperature while it was charging and getting some sun exposure. It doesn't happen frequently but it does happen occasionally. OTOH my GNS530W has never even denied me an LPV/glideslope approach.

Having an EFB does not make one's plane a /G no matter what Mike's lunch-buddy says.

[Mooneymite]

10 minutes ago, cnoe said:

OTOH my GNS530W has never even denied me an LPV/glideslope approach.

Be aware that there is an antenna failure mode in the 430/530 series (I don't know about the later models) that not only disables the panel mount, but also prevents other GPS's from receiving satellite data.  Garmin is well aware of this problem, but mostly keeps quiet about it.

If this happens, one must turn off the 430/530 to allow other GPS devices to regain reception.

https://mooneyspace.com/topic/11114-garmin-430w-gps-antenna-problem/

 

Edited March 2, 2017 by Mooneymite

[cnoe]

Good to know. Thanks.


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[cnoe]

Funny 'cause thinking about it I have 6 separate GPS receivers available in the plane on every flight. I'm not sure how the Garmin could disable reception on all those but I'll certainly keep that possibility in mind.


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[Mooneymite]

Just now, cnoe said:

Funny 'cause thinking about it I have 6 separate GPS receivers available in the plane on every flight. I'm not sure how the Garmin could disable reception on all those but I'll certainly keep that possibility in mind.

The only device that will work in proximity to the problem antenna is one that receives the Glonass constellation.