Tablet computers for IFR

Tom-D

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Tom-D
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
 
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.
 
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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 ?
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.

Lets talk legal with references
21.193 and 91.9(a).
 
Foreflight does not provide any instruments.

The point was if it isn't hard wired and used for flying IFR, can you use any hand held device to navigate such as the hand held GPS with approaches.?

Maybe the iPad and fore flight was a bad example. but tablet computers have many programs that will show you about any thing you wish.

Can you use them legally in a EXP aircraft?
 
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).

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.
 
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.

WINGX has the ability to interface with a portable ARS (a solid-state gyro substitute) which when properly mounted in the airplane gives you a real-time pitch/roll/yaw display. It will use GPS for speed and altitude, if I recall correctly.
 
iCub

LSA Cub type aircraft with an iPad in the panel.
 
I can't vouch for WINGX but I've seen some of the other simulated panel apps for the iPad and the problem is that the accelerometers in the iPad is USELESS unless you've got some way to mount the pad rigidly to the airframe. Otherwise the jiggling of the mount (or you trying to hand hold the thing) is going to drive the instruments all over the place (yes I've tried).

As Tim points out, the external gyro box works better (I've not seen this with the iPad but have with older Pocket PC apps).
 
What I have concluded from the answers here it will not work well, but if the EXP aircraft is in compliance with 91 instrument regulations, it is legal to fly with a tablet computer and the right program/app.
 
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.
 

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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.

Your reference is exactly why all aircraft must meet the requirements of 91 for installed instruments. day& night VFR/IFR

What rule says any other device must be installed?
 
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.
 
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.
 
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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.

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.

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. As far as operations are concerned, there were no restrictions on using the ATC system. (once the test flight time is completed) 91.205 applies to all aircraft, but says nothing about radios, or nav equipment.

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.

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.

As you have said before I see no hard and fast rule.

It is legal to fly a certified aircraft on a hand held radio, they aren't hard wired. so why not this?
 
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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.
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).

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.
This is an issue of operating limitations, not a maintenance requirements.

As far as operations are concerned, there were no restrictions on using the ATC system. (once the test flight time is completed)
The ones I've seen discussed VFR and IFR operations. Not having seen the ones you have, I can't speak to them.

91.205 applies to all aircraft,
No, just to Standard airworthiness category aircraft. See the title:
Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements.
That leaves out Experimental category aircraft, for which these issues are addressed in the operating limitations attached to their airworthiness documentation.

but says nothing about radios, or nav equipment.
Did you read paragraph (d)? Especially item (2)?
(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

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.
See above.

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.
Easy -- 91.9(a), based on what it says in the operating limitations for that particular aircraft.

As you have said before I see no hard and fast rule.
I agree -- it's whatever's specified in that particular aircraft's operating limitations.

It is legal to fly a [Standard] certified aircraft on a hand held radio,
Not under IFR. See 91.205(d)((2) and the Hammerstrand decision.
 
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.

The Hammerstrand decision was all about the violation of equipment rules FAR part 91.205 in standard certified aircraft.

EXP have no such requirements to comply with airworthiness, and FAR 91 has no requirements for how a device is installed, as long as it is "contained" in the aircraft.

Reading the guidance given to the inspector issuing the EXP airworthiness certificate I see no requirement for a restriction on instruments other than 91.205.

134. ISSUANCE OF EXPERIMENTAL AMATEUR-BUILT OPERATING LIMITATIONS.
a. Operating limitations must be designed to fit the specific situation encountered. The ASI may impose any additional limitations deemed necessary in the interest of safety. The ASI and/or designee must review each imposed operating limitation with the applicant to ensure that the operating limitations are understood by the applicant.
b. The following operating limitations shall be prescribed to experimental amateur-built aircraft: *
(1) No person may operate this aircraft for other than the purpose of meeting the requirements of § 91.319(b) during phase I flight testing, and for recreation and education after meeting these requirements as stated in the program letter (required by § 21.193) for this aircraft. In addition, this aircraft must be operated in accordance with applicable air traffic and general operating rules of part 91 and all additional limitations herein prescribed under the provisions of § 91.319(e). These operating limitations are a part of Form 8130-7, and are to be carried in the aircraft at all times and be available to the pilot in command of the aircraft.
End quote

They can issue the restrictions as they see fit. but many EXP aircraft are already in service and have no such restrictions.
 
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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.
 
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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.
 
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.

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.
 
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.

Pretty sure it's legal, but I'd consider a pair of 696 or 796 minimum going that route. There are much more capable systems that are better values for the same money available to Ex/AB.
 
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.

This is why I ask here, rather than going directly to the FAA.

These rules were written long before any of these devices were invented. The EXP aircraft run many devices that are not allowed by the FAA in standard aircraft. There are many glass instrument panels in EXP aircraft that qualify as in compliance with 91.205 and operate in ATC controlled airspace.
The guidance given to the inspectors issuing the airworthy certificate for amateur built EXP gives them the authority to add restrictions to the letter of limitations for that aircraft but they never do unless you built some really really strange.

Part 91 rules never states how a device is installed, that rule simply tells us what equipment we must have, It is not the intent of the rule to tell us how to install stuff.
Part 43 does not pertain to EXP aircraft, it explicitly tells us in the rule its self. So what rule forbids us from operating in IFR by using a hand held device in any EXP aircraft. . ????

I simply think it's a loophole never explored.
 
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:
b. Operating Limitations.
(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]​
(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]
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.
 
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On what regulatory, advisory, or case law basis do you say that?

The fact there is no verbiage excluding it. Where the rules spell out what the specifications for the equipment are don't apply to ex/ab. 91 just says what it has to do.
 
I thought you posted in another thread the local FAA always dropped everything they were doing to take your calls and accommodate you?? :dunno:

Just call them. :rolleyes:

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.

The only guidance that any homebuilder has is the statement that says that the instrument must be installed IAW the instrument manufacturers instructions.

There is no confusion on my part as to what instruments are allowed in standard category aircraft, show me a regulation telling any home builder how a instrument should be installed.



"That particular aircraft" Really ?

All letters of limitations are given to each aircraft EXP home built and apply to that aircraft only, these letters are pretty much a standard letter telling the operator of any restrictions of the aircraft, they will never have any restrictions when the aircraft is equipped as required, and complies with 91.205.

Now once again I ask you to show me where FAR 91 says any thing except "Contains" as a requirement.

Because there are thousands of EXPs out there that already have letters of limitations that allow them to operate in IFR conditions. and the only requirement to do that says they must have the equipment to use the facilities of the approach.

OBTW I liked para c. of your AC reference. :)

c. This AC is not mandatory and does not constitute a regulation. This AC describes an acceptable means, but not the only means, to comply with airworthiness certification and operation requirements of amateur-built aircraft. However, if you use the means described in the AC, you need to follow it in all important aspects.
 
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Why should I stir a pot until I know what 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?

Levy, out.
 
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.

every home builder should be familiar with the guidance given in the FAA instruction 8130-2E, it does not tell the inspector how any equipment is to be installed.

bye ..
 
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