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UK CAA heel dragging on GPS approaches, including LPV (merged)

OK; you might argue that ATC in Class G is meaningless since there is no possible "clearance", which is true, but we have what we have..... Class G ATC still "clears" you for the approach.

Presumably you have centrally funded approach controllers, or have found some other way to prevent multiple aircraft flying the same IAP at the same time. One way might be to self-schedule but AFAIK that proposal is simply too emotionally unacceptable.

The way it works here is that all ATC is performed by employee of DFS (+ soldiers at the military airfields). ATCOs are located in a few centers throughout the country (Langen, Munich, Bremen, Karlsruhe etc.) and in towers at controlled airfields.

When you do an IAP to an uncontrolled airport (e.g. Schwäbisch Hall EDTY which even has an ILS), you get cleared for the approach while in airspace E and shortly before you pop out of E into F, ATC will tell you "you are about to leave controlled airspace, radar service terminates, call Schwäbisch Hall Info at 199.22". By this time, ATC will have called the Info service at the airfield and informed him about the arriving IFR traffic. Info will then issue a "to all stations, airspace foxtrot active, IFR approach on runway 28 5 NM out". This will increase the legal minima from G to F (and scare 99% of VFR pilots who will then stay away). There is no ATC at Schwäbisch Hall, just a regular Info service with some additional training.

Jason, the Alderney LPV approach was certified by the CAA in several different LPV and PRNAV approved G-Reg aircraft. It was published in November 2011 I believe.

THe motivation behind it though is as Peter says - the NDB/DME approach was previously the only way of essentially commercial traffic (The Aurigny Trislanders) getting in and out of Alderney and that is a fairly hairy prospect at minima, which Alderney all-too-regularly endures.

Hence, the LPV has been brought in on 08/26 to provide a fairly decent chance of getting in with weather anywhere that isn't fog, though the DH are 306' and 300' respectively rather than the system minima of 200' due I think to obstacles.

They do exist in the UK though, and both the CAA pilots and examiners are very keen on them. It is the procedural issues regarding design and ATC provision that are holding things up.

London area

In the US, at most of the GA non-towered airports where instrument approaches are available, the surface to 700 AGL is class G. Since the VFR minimums here in class G are 1 SM and clear of clouds, there always exists the possibility of VFR traffic on approaches to these airports. My estimate of WAAS equipped aircraft in the USA that can fly the LPV procedures is at least 25% of the GA fleet and a much higher percentage of the serious IFR aircraft. The LPV is easier to fly than the ILS as it is much steadier and doesn't have the scalloping often seen on an ILS. At my airport KUZA (non-towered with class G to 700 AGL), we have two LPV procedures (one to each runway end 2/20). We also have an ILS to runway 2. We have approach lights (MALSR) for runway 2. The DH for runway 2 LPV is identical to the ILS (200 and 1/2 SM). The LPV to runway 20 does not have approach lights and the minimums are 250 feet and 7/8 SM.

A point of interest here in the US, we also have 400+ LP approach procedures published. In theory, these procedures are somewhat equivalent to a Localizer only approach as they improve on the lateral guidance to the same precision as is used on the LPV, but don't have any vertical guidance. They started getting published two years ago and many of the GPS units are approved to fly the procedure. But as I write this, none have been flown (at least legally) to date because Jeppesen hasn't coded them in the GPS database. This is about to change with the February update cycle as they will finally be included.

KUZA

Well today I flew the LNAV+V into Gloucester and the LNAV/VNAV into Cologne/Bonn. I prefer the GPS approaches. Super accurate all the way to the threshold, my DFC 90 auto sequences through them. No course setting or procedural ILS tracks. I know equipment is less common in Europe but it just takes a 430w. A lot of these in the IFR fleet.

I understand the silly ATC rule in the UK but I think to say there is no demand is wrong. I find it very odd that you can fly IFR in class G because you think 'I am now IFR' in the UK but can't fly an IAP into a field without ATC.

I assume the LP procedures will also get Garmin glide paths?

EGTK Oxford

it just takes a 430w. A lot of these in the IFR fleet.

No. Many people have made that mistake. The 430W cannot be just screwed into the panel (like many thousands were). Such an install is not even legal for IFR enroute. All it is good for is flying from Shoreham to Lydd at 5000ft (etc)

The minimum you need is an installation (meaning annunciators etc) and an AFMS authorising BRNAV, which gives you IFR enroute. See my KLN94 writeup; URL above. Under EASA, this eventually became a Minor Mod (a few hundred quid, via certain avionics shops).

If you want to fly GPS/RNAV approaches, you need an AFMS authorising those, which also eventually became a Minor Mod (a few hundred quid, via certain avionics shops).

If you want to fly GPS/LPV approaches, you need an AFMS authorising those, which under EASA is a Major Mod (not sure of the cost but some paid about £2000, via certain avionics shops). Under N-reg this is also a Major Mod, done with a 337 (see my KLN94 writeup) but this is now tricky in Europe, due to non-cooperation of the NY IFU.

The only shortcut through the paperwork is to buy a GPS which comes with an EASA STC and an AFMS and currently it is only the GTN650/750 that do, via their AML STC. Obviously, Garmin have now positioned themselves to own the rest of the known universe which they didn't own already...

And bizzarely, due to the NY IFU "business", the Garmin FAA AML STC also makes the 650/750 the obvious choice for an N-reg, too, because you send off the 337 to the FAA for filing so no FSDO interaction is required.

(edit: the GNSx30W also come with an FAA AML STC)

I understand the silly ATC rule in the UK but I think to say there is no demand is wrong.

I am sure there is demand from pilots, but the airfield has to decide on the business case, and IMHO only a tiny % of GA is going to spend the money on LPV. It's a catch-22. There are no LPV approaches so why should they?

Even flying into Europe, I have never come across a case myself where the airport I am going to, which must have Customs, and is IFR capable, doesn't have an ILS but does have a GPS approach (of any kind, never mind LPV). I know there are some but very few. So, operationally, the case is poor. Obviously if you are putting in a GTN650 or 750 then you will get it for free but how many are? I know exactly one UK pilot who has a GTN.

Personally, if I was going to spend money on IFR (as with the full IR) capability, I would get a fully working 3-servo autopilot which can track an ILS down to something like 200-300ft, and I would make sure that install absolutely works. And one which has VS preset, so one can fly a LNAV-only VOR/NDB/GPS approach, by flying to the FAF, dropping the gear etc, noting the GS, looking up the corresponding VS (off the Jepp plate), and setting the AP to fly that VS, and then one can just sit there and watch it all the way down. And that will work everywhere.

I find it very odd that you can fly IFR in class G because you think 'I am now IFR' in the UK but can't fly an IAP into a field without ATC.

Welcome to the twisted UK regulatory climate

I have been severely criticised for saying this elsewhere but if you tried to set up an approach controller who is not an ATCO, or you tried to employ an ATCO but with the working hours / pay structure like that of an A/G, all hell would break loose with the ATC unions. The stakes are just too big to allow such a precedent. There is no way they would allow that, and it is probably a breach of ICAO anyway.

It works elsewhere in Europe and in the USA because the employers of the enroute controllers do not operate cost recovery from the airport at which the pilot then lands. That could also be done in the UK, but good luck with trying to get whoever pays for Farnborough Radar to allocate say 25% of a desk at Farnborough Radar to do approach control for Lee on Solent, Goodwood, Headcorn, Dunsfold, etc

The solutions are trivial, technically.

Administrator
Shoreham EGKA, United Kingdom

Under N-reg this is also a Major Mod, done with a 337 (see my KLN94 writeup) but this is now tricky in Europe, due to non-cooperation of the NY IFU.

So everyone flying these in the US did it via a 337?

All it is good for is flying from Shoreham to Lydd at 5000ft (etc)

Never heard anyone describe flying from Shoreham to Lydd as good! :-)

EGTK Oxford

So everyone flying these in the US did it via a 337?

Yes.

You need an AFMS authorising it and in virtually all cases a custom AFMS means a Major Alteration which is a 337.

You then get two options:

1) Back the 337 with an STC (airframe specific STC, or an AML STC with your airframe on the list) and the 337 is just sent off to the FAA (AFS-750, Oklahoma) for filing, or

2) Process it as a Field Approval, which means a US FSDO has to sign off the 337.

(I understand that GNSx30W do come with an FAA AML STC so those did not have to be done as field approvals.)

Otherwise, you are illegal.

There is a 3rd option: the aircraft manufacturer certified the whole thing in the factory, under their Type Certificate. This is actually a sore point (again, see my KLN94 writeup ) because Socata failed to do this, leaving their factory outlet in Florida to do it for those few who were bothered and knew what to ask for, and the other few hundred TB20/21s in the USA, and in Europe, are flying GPS approaches illegally without knowing.

I know this sounds anal, and I am not defending the process, but that's the way it is.

There are loads of things in aviation which are illegal but for which you can never get done (like flying IMC enroute under "VFR") and there are loads of things in maintenance where one needs to be pragmatic, but this is IMHO a bit different because when you pitch up and ask for a GPS/RNAV or GPS/LPV approach, the whole circus can hear you on the radio

It would be even better if you are not legal for the GPS approaches which you filed at your destination and alternate, and both of them has only GPS approaches That makes the flight illegal before departure.

Before I got the AFMS sorted, I used to ask for the NDB/DME approach at Shoreham but fly it using the GPS in the OBS mode, which is 100% legal

Never heard anyone describe flying from Shoreham to Lydd as good!

I have known of somebody who diverted to Lydd pay £150 for a taxi back to Shoreham

Actually the pub/hotel in the village is not too bad, so long as you don't get your cholesterol tested the next day

Administrator
Shoreham EGKA, United Kingdom

Since 2003, all of the newly released GPS units have been installed in the US via an STC with an Approved Model List. When the term 337 is used, I think you are referring to individual installations where each install had to be field approved by the local FSDO using a 337. This is the process that Peter used with the KLN94 when he upgraded his unit to IFR. The STC with the AML process also uses a 337 to record the modification, but the 337 is filled out by the IA and mailed directly to the FAA for filing without any additional approvals being required.

KUZA

Well I have 650s so it doesn't affect me but still stupid.

Before I got the AFMS sorted, I used to ask for the NDB/DME approach at Shoreham but fly it using the GPS in the OBS mode, which is 100% legal

Would anyone with a brain actually fly an NDB approach other than by using a GPS if they have one?

EGTK Oxford

Since 2003, all of the newly released GPS units have been installed in the US via an STC with an Approved Model List. When the term 337 is used, I think you are referring to individual installations where each install had to be field approved by the local FSDO using a 337. This is the process that Peter used with the KLN94 when he upgraded his unit to IFR. The STC with the AML process also uses a 337 to record the modification, but the 337 is filled out by the IA and mailed directly to the FAA for filing without any additional approvals being required.

Yes, and perhaps this is a tangent but its an area in which I think people are frequently and repeatedly confused.

FAA Form 337 is essentially just the applicants cover memo for the supporting engineering data related to any major modification. That engineering data can conceivably be (1) an engineering package generated by anybody (the old fashioned field approval submission that doesn't 'fly' so often nowadays), or (2) it could be an approved STC or other FAA approved data... like AC 41.13 or even another field approval filed before October 1, 1955 :-), or (3) it could be an engineering package generated by a DER authorized to work on the job. The first of those requires field approval, meaning the local FAA FSDO has to sign off on the 337 and supporting data before installation. The latter two utilize (pre)approved data, meaning no field approval is necessary for installation.

The FAA field approval process is described here, including the cases where an STC or other approved data is used and no field approval is actually required.

http://www.faa.gov/aircraft/aircert/designapprovals/fieldapprovals/fieldapprov_proc/

PS Peter I noticed a very minor error in your write-up in that the FSDO approves the 337 in Block 3, not Block 5. Like this - http://www.taylorcraft.org/docs/alternate%20skylight%201.pdf

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