/I Equipment suffix for panel mount VFR GPS.

[jetdriven]

A few days ago  filed IFR M20P/I for a trip to New Orleans from Houston, twice. We have a VFR installation of a  KLN-89B GPS and an aera 500 and iPad. I also put "VFR GPS" in the remarks.

Per the FAA, the "/I" equpment suffix means " LORAN, VOR/DME, or INS, transponder with Mode C"

Anyways, the controllers cleared me to several downrange fixes enroute, and I cancelled IFR and did the visual to New Orleans, and the VOR/B to KLVJ.

 

My copilot helper thinks I misrepresented my aircraft to the FAA, and that I was in the wrong.

 

My position is this:

• 
  
• The FAA never got around to amending that line in the text to include "VFR GPS" in lieu of LORAN
  
• the LORAN in our J was replaced by a VFR GPS in 1996
  
• it is much more accurate
  
• Controller workload is lower because they know we have enroute IFR capabiltiy
  
• We can navigate enrout much better than the LORAN that was removed
  
• the 747 I fly is RNP-10 (+/- 10 miles enroute) and it has /I FMS, we can do ten times better
  
• We can navigate enroute same or better than LORAN/INS/FMS
  
• I can defend the use of VFR GPS as an equlvalent to LORAN (LORAN is dead anywasy) at a hearing.
  

 

What are your thoughts?  Did I lie to the FAA?  MIsrepresent?  Commit a violation?

 

[OR75]

I am thinking none of the above. From the FAA/atc standpoint if you say that it is avfr gps then it cannot be used for enroute  (same as having a handheld).

The kln89b is tso129 so can be used for enroute navigation.

[N601RX]

For the KLN 89B to be certified for a non precision approach or enroute it has to have.

A TSO'D antenna.  Below a certain serial number were not.

Connected to your encoder.

Connected to an approved annunciator.

Connected to a CDI.

Flight manual Supplement.

I recently installed one in our plane to replace the ADF.  I have a extra annunciator.

 

[xftrplt]

Byron,

Since you elected to try your case in moot court, I'll offer an opinion:

Your logic may be correct, but you weren't /I for reasons expressed above. 

You may try to defend your position to the Feds, but

listen to your copilot, or, as they say, your hearing will improve at the hearing.

(Of course, there's no problem...until there's a problem.)

[Cris]

Per the FAA, the "/I" equpment suffix means " LORAN, VOR/DME, or INS, transponder with Mode C"

Since you are arguing the loran section I would agree with Dick above. However assuming that you have VOR/DME and could identify the downrange fixes when in range and you had VFR GPS in the remarks I would think that you are legal but not because you are substituting a VFR GPS for Loran but rather VOR/DME. To be safe I'd ask the controller for an iniial on course vector to the fix advising that it confirms your VFR GPS.

[bnicolette]

That's a good one.  This is certainly one area where the FAA is really behind IMO.  My handheld GPS from back in the 90's was more accurate and reliable than these older Lorans were.  I don't understand why the FAA wouldn't update their equipment suffix's to allow regular GPS's for at least enroute navigation.  Even the cheap GPS contained in my iPhone is able to maintain RNP10.

I file /I but I am using my KNS80 as the basis for that even though I rarely program it and use one of the three GPS's in my Mooney to go direct. (GPS396, Apollo 360, iPad)

Unfortuneatley, I think that unless you have the listed units for /I, I personally don't think it's legal.  I also don't agree with that logic and it is very outdated.

I suppose the right thing to do would be to file the correct equipment suffix and then just ask for direct.  In a radar enviroment I really don't think it matters what we use to go from point A to B.  I think we can all agree that the VFR GPS's are every bit as accurate as the IFR GPS for enroute navigation.  I always have either the iPad or iPhone up and running along with the other GPS's in my airplane.  I can honestly say that I have never seen one of them say anything different that another in regards to bearing, track, groundspeed, etc..  Has anybody here ever seen anything different between one of their IFR GPS's and their VFR GPS's?  I would be interested to find out?

[xftrplt]

I suppose the right thing to do would be to file the correct equipment suffix and then just ask for direct.

Exactly. 

[John Pleisse]

She is right....

10:1 you would have gotten the same routing just filing  /a anyway.

Just a thought...what would it cost to get the KLN89B converted to enroute only? I know it is throwing good money after bad, but would you have to have all the annunciators? Isn't all that mess in the panel more for the approach cert? I mean, it's already in the panel and doing the same job anyway, right?

[Cruiser]

Quote: jetdriven

snip.... 

What are your thoughts?  Did I lie to the FAA?  MIsrepresent?  Commit a violation?

 

[gregwatts]

Quote: Bnicolette

That's a good one. This is certainly one area where the FAA is really behind IMO. My handheld GPS from back in the 90's was more accurate and reliable than these older Lorans were. I don't understand why the FAA wouldn't update their equipment suffix's to allow regular GPS's for at least enroute navigation. Even the cheap GPS contained in my iPhone is able to maintain RNP10.

I file /I but I am using my KNS80 as the basis for that even though I rarely program it and use one of the three GPS's in my Mooney to go direct. (GPS396, Apollo 360, iPad)

Unfortuneatley, I think that unless you have the listed units for /I, I personally don't think it's legal. I also don't agree with that logic and it is very outdated.

I suppose the right thing to do would be to file the correct equipment suffix and then just ask for direct. In a radar enviroment I really don't think it matters what we use to go from point A to B. I think we can all agree that the VFR GPS's are every bit as accurate as the IFR GPS for enroute navigation. I always have either the iPad or iPhone up and running along with the other GPS's in my airplane. I can honestly say that I have never seen one of them say anything different that another in regards to bearing, track, groundspeed, etc.. Has anybody here ever seen anything different between one of their IFR GPS's and their VFR GPS's? I would be interested to find out?

[bnicolette]

Quote: gregwatts

[Becca]

Quote: xftrplt

I suppose the right thing to do would be to file the correct equipment suffix and then just ask for direct.

Exactly. 

[jetdriven]

Sinde we have dual VOR and DME does it qualify for /I under that?

[jetdriven]

Quote: Cruiser

 Yes, Yes, Yes.

your suffix is for IFR CERTIFIED equipment approved for IFR use in your plane.

[Cris]

Quote: jetdriven

Sinde we have dual VOR and DME does it qualify for /I under that?

[OR75]

LORAN C could be approved for enroute navigation when installed under TSO C60B & C115A. The ARNAV FMS 5000 comes to mind when thinking about an IFR enroute unit.

[gregwatts]

Quote: Bnicolette

[jetdriven]

between the aera 500, KLN-89B, iPad, and iPhone, they are all within .1-.2 NM at 99 NM.  they always show the same mileage above 100

[1964-M20E]

Another way is to file the route using VORs and then ask the controller for a vector of XX degrees between your current position and the airport or fix you want to go to.  Then you are on a vector from ATC. You follow the vector on your VFR GPS in the IFR system.  You can remain on that vector as long as each controller gives it to you.

[Cruiser]

Quote: jetdriven

Sinde we have dual VOR and DME does it qualify for /I under that?

[Cris]

It would seem to me that the equipment designation of / I   "Loran, VOR/DME or INS with transponder Mode C" makes a VOR/DME perfectly acceptable under this designation. Keep in mind the FAA still considers ground based equipment as "primary".  It is not "VFR" equipment assuming the monthly accuracy checks have been made in order to operate within the ATC sustem. IFR/GPS enroute/approach equipment on the other can not be used as primary unless there is back up ground based equipment. This is due to the raim  issues on some equipment like the KLN 94. There are some differances with the newer GPS units as I recall. In any event intersections are often identified with a distance and radial from a VOR so assuming you can get close enough to receive the signal should be able to navigate albeit less easily than with a KNS 80 or GPS.  Note: The equipment list does not say loran "with" VOR/DME as it does with some of the other designators but rather "or". the statement also uses "with" to add the in this case the Mode C transponder.       

[John Pleisse]

It's just like the header on an instrument plate. Minimun required equipment, not "choose either".

[xftrplt]

Quote: gregwatts

As I descend and get closer to the airport.......the gap closes. I believe that the 696 measuresthe distance from the airport to the unit....whereas the 430 measures from the airport to a point on the ground over which I am flying. The discrepancy only exists when the fix is an airport. A geometry thing.....I guess

[jlunseth]

Quote: Cris

It would seem to me that the equipment designation of / I   "Loran, VOR/DME or INS with transponder Mode C" makes a VOR/DME perfectly acceptable under this designation. Keep in mind the FAA still considers ground based equipment as "primary".  It is not "VFR" equipment assuming the monthly accuracy checks have been made in order to operate within the ATC sustem. IFR/GPS enroute/approach equipment on the other can not be used as primary unless there is back up ground based equipment. This is due to the raim  issues on some equipment like the KLN 94. There are some differances with the newer GPS units as I recall. In any event intersections are often identified with a distance and radial from a VOR so assuming you can get close enough to receive the signal should be able to navigate albeit less easily than with a KNS 80 or GPS.  Note: The equipment list does not say loran "with" VOR/DME as it does with some of the other designators but rather "or". the statement also uses "with" to add the in this case the Mode C transponder.       

[bnicolette]

Quote: xftrplt

As I descend and get closer to the airport.......the gap closes. I believe that the 696 measuresthe distance from the airport to the unit....whereas the 430 measures from the airport to a point on the ground over which I am flying. The discrepancy only exists when the fix is an airport. A geometry thing.....I guess