Why wasn’t an electronic copy good enough?

Vance Breese

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Vance Breese
I was at the Wings Over Camarillo Air Show Sunday and a Volt pulled up in front of where I was parked with a friend who also flies an experimental gyroplane. A representative of the Van Nuys FSDO asked for our paperwork. My friend did not have his operating limitations with him.

He called his wife and she sent them to his smart phone. The representative of the FSDO wanted to see a hard copy so my friend went to the local flight school and made paper copies.

Why isn’t an electronic copy of the operating limitations good enough?
 
Because you might alter it....

Tim (said in a very sarcastic voice)
 
An electronic copy IS good enough (though your friend didn't actually have an electronic copy when he was asked, which is a problem). Setting aside the question of whether your friend's smart phone constitutes an EFB, it seems that neither your friend nor the ASI was sufficiently familiar with AC 91-78, which sets forth the FAA's policy on electronic flight bags, etc.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91_78.pdf
 
An electronic copy IS good enough (though your friend didn't actually have an electronic copy when he was asked, which is a problem). Setting aside the question of whether your friend's smart phone constitutes an EFB, it seems that neither your friend nor the ASI was sufficiently familiar with AC 91-78, which sets forth the FAA's policy on electronic flight bags, etc.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91_78.pdf

That's not correct. OPLIMS are part of an E-AB aircraft's Air Worthiness Certificate. IAW AC 20-27G and FAA Order 8130.2J, the original AWC and it's associated OPLIMS are required to be on-board the aircraft any time it's operated.
 
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Operating Limitations are part of the Airworthiness Certificate and must be carried onboard the aircraft just like the certificate itself. And just like the Airowrthiness Certificate and the Registration, they are not EFB eligible.
 
Because the government worker wanted to flex his "power"
 
What is with these ramp checks?
Does similar happen in other parts of our lives?
Can a police officer stop you, if you are not meandering, speeding, swigging from a bottle of beer etc?
Can they stop you on the street and ask for your walking papers, if you are not seen or suspected of breaking the law?
 
I have seen multiple ramp checks at two airshows.
In both cases, as long as you were polite it was instructional and designed to get people in compliance.
The one guy who did act like asshat the FAA rep did give a lot of grief too him.

Tim
 
There was a nice long time FAA person who rained in the young trainee. I felt they were all very amicable and trying to get my friend to do things that were possible.

Part of my pre-flight list is a list of required documents.

When I fly in an air show I am typically checked by two FAA representatives.

This is the second time I have been ramp checked at Camarillo when not flying in an air show..

I have also been checked at Santa Paula.

I had a client with me and it was a good lesson for him and i suspect my friend will remember.
 
What is with these ramp checks?
Does similar happen in other parts of our lives?
Can a police officer stop you, if you are not meandering, speeding, swigging from a bottle of beer etc?
Can they stop you on the street and ask for your walking papers, if you are not seen or suspected of breaking the law?
Well, how about those DUI checkpoints they set up to nab drunks on the way home from the bar. Drove through many of those living on the beach. I guess if you are driving after curfew you are suspect. Was always annoying, here is my license, no I'm not drunk, have a nice night.
 
What is with these ramp checks?
Does similar happen in other parts of our lives?
Can a police officer stop you, if you are not meandering, speeding, swigging from a bottle of beer etc?
Can they stop you on the street and ask for your walking papers, if you are not seen or suspected of breaking the law?
I have been stopped at a DUI checkpoint.
Since these DUI checkpoints regularly ensnare people who haven’t been drinking and driving, questions quickly arose about whether the checkpoints constituted an unreasonable search and seizure. The Supreme Court weighed in on the question in a 1990 decision and determined that DUI checkpoints are in fact a legal and valid law enforcement method.
http://traffic.findlaw.com/traffic-stops/are-dui-checkpoints-legal-.html
 
That's not correct. OPLIMS are part of an E-AB aircraft's Air Worthiness Certificate. IAW AC 20-27G and FAA Order 8130.2J, the original AWC and it's associated OPLIMS are required to be on-board the aircraft any time it's operated.

Interesting, I didn't know that about E-ABs. The EFB AC explicitly says POHs (and presumably AFMs) are EFB eligible, and in most certified airplanes the AFM/POH is the primary source of operating limitations. It's interesting that E-ABs differ in that respect.
 
An electronic copy IS good enough (though your friend didn't actually have an electronic copy when he was asked, which is a problem). Setting aside the question of whether your friend's smart phone constitutes an EFB, it seems that neither your friend nor the ASI was sufficiently familiar with AC 91-78, which sets forth the FAA's policy on electronic flight bags, etc.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91_78.pdf

Interesting, I didn't know that about E-ABs. The EFB AC explicitly says POHs (and presumably AFMs) are EFB eligible, and in most certified airplanes the AFM/POH is the primary source of operating limitations. It's interesting that E-ABs differ in that respect.

So I guess you learned something. Funny though how your first reply was posted with such certainty and included questioning the ASI's knowledge. I guess maybe he was right.
 
So I guess you learned something. Funny though how your first reply was posted with such certainty and included questioning the ASI's knowledge. I guess maybe he was right.

I guess in the original post I didn't notice that OP had mentioned it was an experimental. Had I caught that, I'd likely have responded differently (or at least qualified my response a little more).
 
I have seen multiple ramp checks at two airshows.
In both cases, as long as you were polite it was instructional and designed to get people in compliance.
The one guy who did act like asshat the FAA rep did give a lot of grief too him.

Tim
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.

Not sure what the problem is for someone having the required documentation onboard the aircraft. I carry everything in my flight bag, no big deal.
 
It's because OPLIMS are not part of the AFM/POH. They are a supplement to the AWC and as such have to physically be with the AWC otherwise you aren't legal.
 
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.
Seems to me as if it was a simple safety check. I didn't read where the pilot was cited or hassled because he did not have the operating limitations on board at all in any form. I don't think that having the ability to call someone to have them send them to your smart phone technically counts as having them on board.
 
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.

Not sure what the problem is for someone having the required documentation onboard the aircraft. I carry everything in my flight bag, no big deal.

Depends, except for the a**hat who yelled at the FAA, the agents were there just to make sure everyone was in compliance. They worked with people to get them into compliance, I had to help one guy use our HOA fax machine to get a temp registration; on a Saturday!. Like I said, it was done in a classy way to educate and help. And is a great way to get a bunch of pilots. Now, if they are holding everyone's feet to the fire, I get it why you would not like it.

Tim
 
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.

Not sure what the problem is for someone having the required documentation onboard the aircraft. I carry everything in my flight bag, no big deal.

Inspectors are actually discouraged from performing ramp checks at fly-ins (other than of performers). From FAA Order 8900.1:
"Under no circumstances should these gatherings be targeted for a blanket sweep inspection of spectator airmen and aircraft."
 
My friend wasn’t hassled or cited.

There was an older, more experienced FAA representative reining in his two trainees and showing them how to manage the lack of operating limitations. In the end it was resolved when my friend produced the hard copies of what was on his operating limitations on his phone.

All the FAA representative asked me for was registration, airworthiness and operating limitations.

He did not ask me for my pilot’s certificate, weight and balance, POH, my instructor certificate or my letter of deviation authority even though he was aware that I was on a training mission.

The FAA representative was a nice polite young man and suggested that the signature on my airworthiness certificate was fading and I should have it replaced before someone rejected it as being unreadable.

They may have targeted my aircraft because it looks more homebuilt than most gyroplanes.
 

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What is with these ramp checks?

Maybe it has to do with Federal law?

49 U.S. Code § 44709 - Amendments, modifications, suspensions, and revocations of certificates

(a)Reinspection and Reexamination.—
The Administrator of the Federal Aviation Administration may reinspect at any time a civil aircraft, aircraft engine, propeller, appliance, design organization, production certificate holder, air navigation facility, or air agency, or reexamine an airman holding a certificate issued under section 44703 of this title.
section 44715(a) of this title;
 
Oh come on, I know what the law says! I am asking if we are to remain contently quiet while these activities continue? Ie; do you agree with the law. My opinion: "Baa-aaa."
 
I would prefer to fly with licensed pilots flying airworthy aircraft.

I am comfortable with ramp checks as part of how to get there.

I am amazed at how much the FAA leaves us alone.

I have seen aircraft that are dangerous flown by pilots with little regard for the rules or my safety.

I feel we have a nice balance in the USA.
 
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not that any sane person would do this, but what if you just walked away when ramp checked? Can they arrest you on the spot?
 
Oh come on, I know what the law says! I am asking if we are to remain contently quiet while these activities continue? Ie; do you agree with the law. My opinion: "Baa-aaa."

It's not a matter of agreeing with the law. Say you disagree all you want, that doesn't change anything.
 
not that any sane person would do this, but what if you just walked away when ramp checked? Can they arrest you on the spot?

The FAA can't arrest anyone. However they can make sure the aircraft doesn't fly until they are satisfied, as well as take action against the owner/pilot.

If you were pulled over by the police for a routine traffic stop, would you just drive away?
 
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.

Not sure what the problem is for someone having the required documentation onboard the aircraft. I carry everything in my flight bag, no big deal.

The FAA actually addresses this issue in their guidance to inspectors. Refer to the bold item below in FAA Order 8900.1, Volume 6, Chapter 11, Section 10,"Surveillance of an Aviation Event":

6-2373 GENERAL.

A. Surveillance Policy. Air shows, fly-ins, and other gatherings of general aviation aircraft and airmen are opportunities for the Federal Aviation Administration (FAA) to present a positive image to the aviation community with whom we work and the general public. Many of the aircraft operators attending these aviation events are regular users of our air traffic and flight service facilities, but their contact with Flight Standards personnel may have been rare. Most of the people who fly their airplanes to fly-in events and air shows are aviation enthusiasts and hobbyists and are not employed in the aviation industry as pilots.

1) The FAA would like this important segment of airspace users to have a very positive image of inspectors and the safety activities inspectors perform. Therefore, the FAA encourages inspectors to establish early contact with sponsors and organizers of aviation events so that informational and FAA Safety Team activities can be planned to serve attendees.

2) Under no circumstances should these gatherings be targeted for a blanket sweep inspection of spectator airmen and aircraft.

3) The scope of surveillance conducted on aviation event performers and their aircraft will be determined by the Flight Standards District Office (FSDO) manager.

4) Inspectors assigned work functions at aviation events should strive to earn the confidence of the attending and participating airmen. This can be accomplished by displaying expert technical knowledge as an aviation safety professional.

5) The guidance in this section does not preclude inspectors from taking appropriate action to resolve situations they observe that require immediate corrective action.
 
The FAA can't arrest anyone. However they can make sure the aircraft doesn't fly until they are satisfied, as well as take action against the owner/pilot.

If you were pulled over by the police for a routine traffic stop, would you just drive away?

Driving away from a traffic stop can in fact get you arrested. Walking away from a ramp check is just likely to end with certificate action.
 
It's not a matter of agreeing with the law. Say you disagree all you want, that doesn't change anything.

For me it is exactly about 'do we agree with the law'!
And change is possible! Plenty of bad laws have been changed over time; in fact it happens every single day. The day we give up and say, "they win" is the day we stop becoming Americans!
 
Did you think ,he may have needed a hard copy for his records,unless you wanted to give him your phone,as a record.
 
I don't feel an airshow is the place for the FAA to stretch there mussels and perform ramp checks, but I do see them checking someone performing in the airshow because public safety a factor.

Not sure what the problem is for someone having the required documentation onboard the aircraft. I carry everything in my flight bag, no big deal.
That depends on a which mussels the FAA was stretching, eh?

4bed5f6aa6ac6e34c7ef583f9446e1e1.jpg
 
slightly tangent question: can FAA ramp check foreign aircraft? If so, is the process different than N numbered aircraft?
 
For me it is exactly about 'do we agree with the law'!
And change is possible! Plenty of bad laws have been changed over time; in fact it happens every single day. The day we give up and say, "they win" is the day we stop becoming Americans!

Then start the process to repeal 44709 and replace it with the language that will make you happy. I'm sure you can get enough congressmen and senators to back a Bill and get it sent up to the President for a signature.

Lots of luck. Oh, BTW, in the mean time 44709 is the law.
 
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