So this comes from the Category 1 requirements list (I have abbreviated it to include only CAT 1)
19.04 NAVIGATION SYSTEMS
(a) Mounted GPS.
(b) Back up GPS.
(c) Second back up GPS OR sextant, timepiece & tables with ability to use.
(d) Echo (Depth) Sounder.
(e) Log or distance measuring instrument.
(f) Radar (recommended)
So they don't make a distinction between a handheld and the "mounted". I guess a permanently "installed" Garmin 76 would be hard to argue with.
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