b350capt said:
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.
Sure they are:
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f. Use of GPS in lieu of ADF and DME
1. Subject to the restrictions below, operators in the U.S. NAS are
authorized to use GPS equipment certified for IFR operations in place of ADF and/or DME equipment for en route and
terminal operations. For some operations there is no requirement for the aircraft to be equipped with an ADF or DME receiver, see subparagraphs f6(g) and (h) below. The ground-based NDB or DME facility may be temporarily out of service during these operations. Charting will not change to support these operations.
(a) Operations allowed:
(1)
Determining the aircraft position over a DME fix. GPS satisfies the 14 CFR Section 91.205(e) requirement for DME at and above 24,000 feet mean sea level (MSL) (FL 240).
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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.
We are reading this stuff two completely different ways. I read the italics as saying what I said before - you can't fly an NDB approach just using a GPS.
But you =can= identify an NDB or DME fix (say an OM) on a VOR approach with GPS (so long as you are using VOR for course guidance).
The difference is course guidance vs fix location. You cannot use the GPS for course guidance (overlay) unless the approach plate says "GPS" on it. But you =can= use GPS to locate fixes, even if they are DME or ADF-based and even if you are flying a VOR "terminal procedure," AIM 1-11-19.f.1.c. even tells you how.
That's why new piston singles (not glass) come IFR equipped with VOR/LOC/Glideslope, but no DME or ADF receiver.
I really think you are incorrect on this. As I recall, AOPA worked with the FAA on this specific issue years ago.
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f. Use of GPS in lieu of ADF and DME
1. Subject to the restrictions below, operators in the U.S. NAS are authorized to use GPS equipment certified for IFR operations in place of ADF and/or DME equipment for en route and
terminal operations. For some operations there is no requirement for the aircraft to be equipped with an ADF or DME receiver, see subparagraphs f6(g) and (h) below. The ground-based NDB or DME facility may be temporarily out of service during these operations. Charting will not change to support these operations.
(a) Operations allowed:
(1)
Determining the aircraft position over a DME fix. GPS satisfies the 14 CFR Section 91.205(e) requirement for DME at and above 24,000 feet mean sea level (MSL) (FL 240).
==============================