This bulletin is rather encouraging:
https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=11152
This will be especially helpful for (often newer) aircraft not equipped with legacy equipment like ADF. This has been allowed in the US for years but it’s nice to finally catch up in Europe (well, the UK at least).
channel-hopper wrote:
This bulletin is rather encouraging:https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=11152
This will be especially helpful for (often newer) aircraft not equipped with legacy equipment like ADF. This has been allowed in the US for years but it’s nice to finally catch up in Europe (well, the UK at least).
The problem is that this looks a guidance manual… What is the law? PART-NCO? ANO? When and where is this introduced?
arj1 wrote:
The problem is that this looks a guidance manual… What is the law?
Does it matter? This appears to be an official CAA publication and clearly states that it is guidance. There should be zero legal risk of following official CAA guidance. On the contrary, following official CAA guidance should be a very strong legal defence in any “prosecution”. I would class this similarly to FAA AIM information. It is not the law, but following AIM guidance is a good CYA to keep out of trouble.
chflyer wrote:
Does it matter? This appears to be an official CAA publication and clearly states that it is guidance. There should be zero legal risk of following official CAA guidance. On the contrary, following official CAA guidance should be a very strong legal defence in any “prosecution”. I would class this similarly to FAA AIM information. It is not the law, but following AIM guidance is a good CYA to keep out of trouble.
It does, because it does not specify WHEN it comes into force! :)
Another complication is that GPS fix substitution comes into force in the EU as a result of NPA2020-02, which also contains some other things.
Are they coming into force in the UK as well?
Yes CAPXXX are CAA sort of “soft laws” like GM…
Sounds like brilliant news for UK GA, probably more useful than current draft in EASA rules (especially DME?), now hopefully, the one or two dinosaurs in the field will upgrade themselves, honestly, people really don’t have time to wait for them to pass away 
RNAV substitution shall be restricted to operators/pilots authorised for either RNAV 1,
RNP 1 or Advanced RNP.
This is not available to KLN94 owners, which is dumb bcause it is just as accurate as a GNS/GTN/etc
RNAV substitution for ADF, VOR or DME may be used where the aircraft equipment is not
installed or is inoperative and/or the ground-based radio navigation aid is either inoperative
or unreliable.
That’s good.
For VOR and DME, RNAV Substitution should not encourage operators/pilots to
remove VOR or DME, which remain as standard equipment.
Who wrote that bit??
Peter wrote:
This is not available to KLN94 owners, which is dumb because it is just as accurate as a GNS/GTN/etc
Agree. They should consider changing the requirements to be able to meet the RNP APCH specification, which includes RNAV 1 for terminal mode before switching to an approach mode.
Peter wrote:
RNAV substitution shall be restricted to operators/pilots authorised for either RNAV 1,
RNP 1 or Advanced RNPThis is not available to KLN94 owners, which is dumb bcause it is just as accurate as a GNS/GTN/etc
The quote is about operator/pilot authorisation, not equipment/installation authorisation. In EASA-land (at least) RNAV/RNP 1 authorisation is automatic for part-NCO operations. I don’t know about A-RNP.
If this is PBN, then this concession is not usable for IMCR holders, because the PBN signoff isn’t a requirement for the IMCR.
Before we go over board in excitement here:
“RNAV Substitution may be used in all phases of flight in UK airspace, except to provide lateral guidance in the final approach segment of an Instrument Approach Procedure (IAP).“ (Page 8).
So all this guidance does is legalizing what is already common and undisputed practice everywhere (or when did you last check in the AIP if that enroute Waypoint is really officially defined by a GPS-Position and not by VOR/NDB/DME).
I don’t know a single pilot that would react to a “D-… cleared direct TRA” other than typing TRA in the GPS – although at least I belive (haven’t checked) that the official definition of TRA is still the VOR and not the GPS-location.
