No hard-and-fast rule for Experimentals as there is for Standard category aircraft in 91.205. It's a matter of what's written in the operating limitations for that particular aircraft. However, I suspect the FAA has guidelines in some AC about the establishment of those operating limitations and that the Airworthiness Inspector or DAR signing the paperwork will probably use those when establishing them for that particlar aircraft.When flying an Experimental is it legal to use a tablet computer as the flight instruments. such as the I-Pad with for flight? Must it be an installed device ?
21.193 and 91.9(a).Lets talk legal with references
Foreflight does not provide any instruments.
No hard-and-fast rule for Experimentals as there is for Standard category aircraft in 91.205. It's a matter of what's written in the operating limitations for that particular aircraft. However, I suspect the FAA has guidelines in some AC about the establishment of those operating limitations and that the Airworthiness Inspector or DAR signing the paperwork will probably use those when establishing them for that particlar aircraft.
21.193 and 91.9(a).
Foreflight does not provide any instruments.
I believe some other software - wingx maybe does provide a "simulated 6-pack" showing groundspeed, GPS altitude, Track and an HSI but of course you can't go flying IFR without using a barometric altitude source, you need an attitude indicator.. also if ATC is vectoring you, you need to fly headings (which the pad won't give you, it only knows your track) because ATC's vectors are made with wind corrections in mind.
Foreflight only gives you a moving map with your position, track, gps altitude, and groundspeed info. Your little airplane symbol will move across the charts (IFR charts included) with striking accuracy. You can zoom in and out with ease, and get a distance/time/MH to any point on the map with a single touch of the finger. And you can look up A/FD info with another touch of the finger.
These functions are useful and make last minute in-flight diversions much easier. Its nice to have your airplane symbol on a sectional- it makes finding a difficult to see airport easy. You can use it for VFR navigation - if you type in two points it will draw a line on those points, and you just fly your airplane on the line.
It is certainly legal to use for in-flight charts, planning and possibly the GPS for en-route nav (doubting this one) but you can't fly approaches with it or really replace any instruments on your 6 pack.
Mostly its useful for pre-flight planning (weather, airmets, tfr's are displayed in a super easy to use fashion) and inflight charts and info lookup.
When flying an Experimental is it legal to use a tablet computer as the flight instruments. such as the I-Pad with for flight?
Must it be an installed device ?
Lets talk legal with references
It must be an installed device. See Administrator v. Hammerstrand (1992), attached. This decision establishes that your wristwatch doesn't count as the required clock because it's not installed. By extension, neither is a conventional laptop or tablet. You'd need to fashion some kind of permanent mount for it.
See Hammerstrand, above. Obviously, the life preservers required for overwater flight aren't going to be "installed," but the flight instruments must be.This is as close as I can get to a FAR requirement.
(a) General. Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a powered civil aircraft with a standard category U.S. airworthiness certificate in any operation described in paragraphs (b) through (f) of this section unless that aircraft contains the instruments and equipment specified in those paragraphs (or FAA-approved equivalents) for that type of operation, and those instruments and items of equipment are in operable condition.
What does "contain" mean? loosely interpreted it could be in the back seat. Tightly it means installed IAW the instrument installation instructions.
See Hammerstrand, above. Obviously, the life preservers required for overwater flight aren't going to be "installed," but the flight instruments must be.
As for what you've seen in the operating limitations in EXP aircraft, your experience differs from mine. The ones I've seen have specific reference to everything from IFR/VFR to day/night, etc. IIRC, in one, it said something to the effect of "IFR flight approved when equipped with all instruments required by 91.205." Of course, since it's an EXP, those instruments don't have to be certified (e.g., you can have a Dynon EFIS for your primary flight instruments), but they would have to be installed and working. I guess if you can figure a way to "install" that iPad, it would be OK, but not if it's loose in the cockpit.
The important part of that decision in this context is the idea that required instruments must be installed, not just loose in the aircraft or on the pilot's wrist (or knee).Hammerstrand, was flying a production build aircraft and was in violation of the 91 requirements, plus he was his own lawyer, and mechanic, with no certificate --- dumb really dumb.
This is an issue of operating limitations, not a maintenance requirements.The letters of limitations for EXP aircraft that I have seen issued lately all say the annual condition inspection will comply with FAR part 43-D That is all the maintenance requirements I've seen.
The ones I've seen discussed VFR and IFR operations. Not having seen the ones you have, I can't speak to them.As far as operations are concerned, there were no restrictions on using the ATC system. (once the test flight time is completed)
No, just to Standard airworthiness category aircraft. See the title:91.205 applies to all aircraft,
That leaves out Experimental category aircraft, for which these issues are addressed in the operating limitations attached to their airworthiness documentation.Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements.
Did you read paragraph (d)? Especially item (2)?but says nothing about radios, or nav equipment.
(2) Two-way radio communication and navigation equipment suitable for the route to be flown.
See above.FAR 91 is operations rules as we both know, and do not make a difference between EXP and production built, as to what instruments are required.
Easy -- 91.9(a), based on what it says in the operating limitations for that particular aircraft.Knowing there is no type design on EXP aircraft and no standard of airworthiness to violate, how can the FAA violate you for using the Tablet computer for navigations/ approaches? FAR 91 does not say the equipment must be mounted.
I agree -- it's whatever's specified in that particular aircraft's operating limitations.As you have said before I see no hard and fast rule.
Not under IFR. See 91.205(d)((2) and the Hammerstrand decision.It is legal to fly a [Standard] certified aircraft on a hand held radio,
The important part of that decision in this context is the idea that required instruments must be installed, not just loose in the aircraft or on the pilot's wrist (or knee).
This is an issue of operating limitations, not a maintenance requirements.
The ones I've seen discussed VFR and IFR operations. Not having seen the ones you have, I can't speak to them.
No, just to Standard airworthiness category aircraft. See the title:
That leaves out Experimental category aircraft, for which these issues are addressed in the operating limitations attached to their airworthiness documentation.
Did you read paragraph (d)? Especially item (2)?
See above.
Easy -- 91.9(a), based on what it says in the operating limitations for that particular aircraft.
I agree -- it's whatever's specified in that particular aircraft's operating limitations.
Not under IFR. See 91.205(d)((2) and the Hammerstrand decision.
You asked the question, you got the answer based on the regulations and case law, you rejected the answer in favor of your own interpretation which ignores the plain language of the cited regulations and documents. So why did you bother asking?
Good luck, Tom.
Because I don't believe your case law fits the situation of the EXP aircraft that has no standard for airworthiness.
These devices weren't invented when the regulations were written.
Of all the letters of limitations that I have read, I have never seen a statement restricting the use of the aircraft in IFR conditions. Other than the required instruments listed in 91 for operations in IFR conditions by ALL aircraft operating under part 91 I see no requirements in 21/23 or 91 that these instruments be hard wired / installed .
thus my questions, are all the new equipment, and programs legal to be used in the EXP certificated aircraft.
I have never seen any AC that will answer this question.
On what regulatory, advisory, or case law basis do you say that?Pretty sure it's legal
So long as you don't bend any metal you'll probably be just fine. You could use a ouija board and a toothpick, and so long as you come out where you're supposed to be you with the shiny side up you should be just fine.
Bend some metal or be somewhere you shouldn't and the situation changes. I would be surprised if the FAA didn't make an issue of your iPad. Ron seems to think its an issue, and he's pretty clued in on these things. The FAA makes a deal. You give your interpretation. They disagree. Perhaps you'll come out on top of the dispute, but even then you loose. By the time you get done fighting, what your out in lawyers and time would have bought you a 430 to being with.
Yodice always says hard cases make bad law. This sounds like a perfect example.
So, as I said originally, it's all about the operating limitations for that particular aircraft, and I'd be very interested to see the operating limitations paperwork of an E-AB aircraft which allows IFR flight but doesn't have any direct or indirect reference to instruments which must be installed.b. Operating Limitations.(2) [FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The operating limitations will authorize all operations to be conducted (visual flight rules, day/night, and IFR). These operating limitations may state that the instruments and equipment mandated by § 91.205(b), (c), and/or (d), Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements, need to be installed and operable. In addition, these operating limitations may identify flight test are as defined in § 91.305. [/FONT][/FONT]
(1) [FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]The operating limitations require that you operate the aircraft under the applicable air traffic control and general operating rules of part 91. If you plan to operate under instrument flight rules (IFR), pay particular attention to the applicable requirements in part 91. [/FONT][/FONT]
On what regulatory, advisory, or case law basis do you say that?
This is why I ask here, rather than going directly to the FAA.
I thought you posted in another thread the local FAA always dropped everything they were doing to take your calls and accommodate you??
Just call them.
I do know what topics to approach my PMI with, I'd ask AFS 300. not my PMI.
After all, he's simply a ASI not a rule maker.
Tom is confusing the separate issues of the requirement for certification of the instruments with the requirement to have them installed. In an EXP aircraft, the instruments need not be certified, but they must still be installed. See also AC 20-27:
So, as I said originally, it's all about the operating limitations for that particular aircraft, and I'd be very interested to see the operating limitations paperwork of an E-AB aircraft which allows IFR flight but doesn't have any direct or indirect reference to instruments which must be installed.
So why don't you ask AFS-300??
Why should I stir a pot until I know why it contains?
Tell you what -- since you're so sure it's OK, just do it and don't bother asking anyone. That way, if you get caught and the inspector asks, you can honestly claim ignorance (for all the good that will do you). Or do you think an inspector will be more forgiving if you tell the inspector that someone whose name you don't know told you on an internet discussion board it was legal?Why should I stir a pot until I know what it contains?
Tell you what -- since you're so sure it's OK,
NO I'm not sure it is OK, prove to me why it isn't.
just do it and don't bother asking anyone. That way, if you get caught and the inspector asks, you can honestly claim ignorance (for all the good that will do you). Or do you think an inspector will be more forgiving if you tell the inspector that someone whose name you don't know told you on an internet discussion board it was legal?
Levy, out.