if you further read F.1 it clearly states the operations approved for GPS in lieu of dme/adf which is what i posted earlier. Approach substitutions are NOT oh that list. Also if you read the note listed after 1-1-19(f)(1)(a)(6) you will see the following -
NOTE-
This approval does not alter the conditions and requirements for use of GPS to fly existing nonprecision instrument approach procedures as defined in the GPS approach overlay program.
Here is what 1-1-19(e)(3) says
3. The GPS Approach Overlay Program is an authorization for pilots to use GPS avionics under IFR for flying designated nonprecision instrument approach procedures, except LOC, LDA, and simplified directional facility (SDF) procedures. These procedures are now identified by the name of the procedure and "or GPS" (e.g., VOR/DME or GPS RWY 15). Other previous types of overlays have either been converted to this format or replaced with stand-alone procedures. Only approaches contained in the current onboard navigation database are authorized. The navigation database may contain information about nonoverlay approach procedures that is intended to be used to enhance position orientation, generally by providing a map, while flying these approaches using conventional NAVAIDs. This approach information should not be confused with a GPS overlay approach (see the receiver operating manual, AFM, or AFM Supplement for details on how to identify these approaches in the navigation database).
I think it makes it clear that GPS substitutions for approaches on non-overlay approaches are not allowed, and are advisory only. of course thats only my thinking, lol
NOTE-
This approval does not alter the conditions and requirements for use of GPS to fly existing nonprecision instrument approach procedures as defined in the GPS approach overlay program.
Here is what 1-1-19(e)(3) says
3. The GPS Approach Overlay Program is an authorization for pilots to use GPS avionics under IFR for flying designated nonprecision instrument approach procedures, except LOC, LDA, and simplified directional facility (SDF) procedures. These procedures are now identified by the name of the procedure and "or GPS" (e.g., VOR/DME or GPS RWY 15). Other previous types of overlays have either been converted to this format or replaced with stand-alone procedures. Only approaches contained in the current onboard navigation database are authorized. The navigation database may contain information about nonoverlay approach procedures that is intended to be used to enhance position orientation, generally by providing a map, while flying these approaches using conventional NAVAIDs. This approach information should not be confused with a GPS overlay approach (see the receiver operating manual, AFM, or AFM Supplement for details on how to identify these approaches in the navigation database).
I think it makes it clear that GPS substitutions for approaches on non-overlay approaches are not allowed, and are advisory only. of course thats only my thinking, lol