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Subject: Handheld Mounts
 
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pantherAirborneUser is Offline
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Posts:52

03/14/2013 5:59 PM  
Hey Guys,
I have seen and heard some questions about handheld mounts in the aircraft. I.E. Ram Suction cup mount, windscreen mount. I have not been able to find anything in the FAR's or AIM or the FAA website that specifically says they cannot be used in an aircraft. But I have heard from a lot of people that the FAA has said they are illegal to use them in an aircraft.

Here is a snippet from a recent discussion.

"any time something is mounted in an aircraft (inside or outside) it has to be installed with a logbook entry. in order to make that entry, the mechanic needs approved data to cite. Ram does not provide approved data and as such it would need to be installed under a field approval (I have done this for the ram mount in my aircraft) where the installer creates the data acceptable to the FAA inspector and if he accepts it, the item can be installed with block 3 on the 337 form signed by the FAA inspector and a logbook entry. of course the approval is for that aircraft serial number only, but usually getting one approved makes the approval in other like aircraft easier. by the way if you are involved in an accident and you have one of these mounts installed without an approval, an insurance company can get out of their coverage by stating the the aircraft was being flown in an unairworthy condition as it had an illegal installation (even if the installation is totally unrelated to what happened), you might scoff at this but i have been an expert witness in several cases recently and have seen this happen more than once. The FAA representative called to the stand will agree with the insurance company and the insured is now without coverage of any kind. good luck with that..."

Does anyone have any reference or legal standing they know of that might apply to this?
rskoreckiUser is Offline
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Posts:10

05/17/2013 4:13 PM  
Hey there,

If you look at AOPA's site you can find a link to a letter they wrote to the FAA asking for clarification as to what constitutes an "installation" back in 1999. They are still waiting on a reply from the FAA. Just last week I asked AOPA if they ever heard back, and this is the reply I got...

"Thank you for contacting the Pilot Information Center. We have STILL not heard back from the FAA on this subject, and they also have not given any clarification whatsoever in the form of regulations, or a Letter of Interpretation. "

I use a mount that clips to the glareshield of whatever I am flying. It does not require tools to attach (uses clips instead) and can be removed in less than 0.5 seconds if I want. According to everyone I've asked (with one exception), it does not require a logbook entry as it is not "installed." I've only had one FAA inspector give me grief about it...and I then pointed out that AOPA asked the FAA for clarification in 1999, and that there has been no response.

The operators I've worked for over the past 8 years have all gone with the rationale that if it doesn't require tools and is not permanently attached, then it is not an "installation". Hence the rampant use of adhesive velcro for all sorts of stuff.

Here are links to two relevant AOPA articles about this. Show this to anyone who tries to tell you that you can't attach your gps without a logbook entry. If the FAA was at all interested in being clear about this, then surely 14 years is adequate time for them to respond.

http://www.aopa.org/whatsnew/regulatory/handheldletter.html

http://www.aopa.org/whatsnew/regulatory/reghandheld.html

Good luck!
pilot135pdUser is Offline
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05/26/2013 9:08 AM  
Panther, are you talking about flying Part 91 or Part 135 because it makes a difference.

Carlos

Self discipline is when you do something that you know is right even though you don't want to do it. As a professional and safe pilot you have to maintain control over your desires & emotions. Have INTEGRITY and great WORK ETHIC and you'll succeed in life.
pantherAirborneUser is Offline
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Posts:52

05/26/2013 1:22 PM  
Hey Carlos. Haven't seen you post here lately. I probably haven't been watching as much either. I am mainly referring to part 91 in regards to mounting. I have done some digging around in part 135 but haven't found the specific areas that refer to mounting anything temporarily. I know the portable GPS devices falls under the same verbiage as part 91 and once I start flying 135 I will just use my ipad in a kneeboard strap so I don't have to deal with the whole mounting issue. Can you point me to anything in the 135 regs that relate to this? -David
pantherAirborneUser is Offline
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05/26/2013 1:23 PM  
RS,
I have seen the original letter AOPA sent to the FAA and I was going to contact them also to see if there was any kind of update. Thanks for the reply.
pilot135pdUser is Offline
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05/26/2013 2:09 PM  
This topic in itself is simple. The problem starts when any normal person tries to understand the way Regs are written. Remember the 2 main reasons for the Regs:
1- To confuse.
2- To confuse more.

The Advisory Circular that deals with the iPad is AC 120-76B

That's the first thing you have to read so you understand the many different ways the Regs talk about the same thing BUT when it comes to applying the Regs you have to be able to distinguish.

In essence it talks about the different types of PED (Personal Electronic Device). They also call them EFB (Electronic Flight Bag) Hardware. It all depends on how you store it and how you use it and what you stored in it but they're basically all the same for this discussion - your iPad.

So now you know about that and want to know if you can attach it. As long as it's a Part 91 operation AND you don't PERMANENTLY attach it the aircraft OR you don't wire it into the electrical system, you're basically free to use yoke mounts, window suction cup, Velcro, duck tape, chewing gum, anything EXCEPT SCREWS to hold it in place on the aircraft. They don't say anything about screwing it into your leg but I'd buy a kneeboard if I were you. We'll talk about Part 135 in a minute.

So now let's attack Part 91 flying. You as a pilot have the same restrictions as the crew of a Part 135 or 121 operation. Part 91.21 says you as PIC are not allowed to use a PED under IFR unless you've determined it won't interfere so it makes you the test pilot and sole responsible to prove it if you are ever in need to in front of the FAA. Are you flying only VFR? Then go for it.

Then you mentioned using the iPad on your knee when you go fly Part 135. You're correct you won't have that particular mounting issue if you strap it to your leg BUT flying Part 135 brings up other issues because you now have 2 masters to please:

1- You have the FAA which in Part 135.144 says that you can't allow the operation of PEDs on ANY aircraft unless the Operator (your boss) has done the required test to make sure it doesn't interfere

AND

2- you also have The Operator (your boss) and it's GOM (General Operations Manual) that might tell you that even though the FAA says it's ok, you will not use them in their aircraft or they might say you can.

The company I fly for has the iPads on their approved PED list in the GOM and we use a suction mount so I'm good to go. I'm very glad we have them approved because in the area I fly we have lots of unlit towers and the iPad has an obstruction database that makes our operation even safer.  Regarding safety, take this from someone who has flown for a few crappy companies during my years who talk about safety but it's all website PR. This company is all about safety and I love it !

I hope that gave you more info and a start on where to go looking for more info.

Carlos

EDIT : This is my post # 1400.  Time funs when you're having flies !!

Self discipline is when you do something that you know is right even though you don't want to do it. As a professional and safe pilot you have to maintain control over your desires & emotions. Have INTEGRITY and great WORK ETHIC and you'll succeed in life.
SupremoUser is Offline
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05/27/2013 9:52 AM  
Carlos What an outstanding reply! I kind of miss being in the field and messing with some of the real jerkoffs that are working for the FAA these days. I wonder if I have made my last flight already... well over 25,000 hours and began my nefarious career as a pilot back in the 50's. 1st Rotor license was issued in 1969. So many changes in the FAR's and the FAA people who try to apply and enforce them. geeez best personal regards Rocky

Risk is the price you pay to avoid a dull life.
pilot135pdUser is Offline
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05/27/2013 10:11 AM  

Thanks Rocky.

I've always tried to give as complete of an answer as I can when I see someone has tried to find the info but is missing just a little direction. I hate it when someone just comes on and asks a question and expects everybody to drop everything and spoon feed them the info they could have found with simply opening the FARs.

Of course then there's the student pilot who can't find anything and doesn't have a good CFI. I've kind of gotten better at determining who's a newbie and just doesn't know where to look and the other pilot who's just plain lazy.

Anyways I get the satisfaction of trying to help and even though sometimes it bites me in ass most of the time it's positive.

Regarding the FAA my last experience with them was as you describe. Inspectors who are just there for the paycheck and don't really care about the safety of the public or anything else. Oh well...

I won't hijack this thread so I'll go post on your other thread now.

Carlos

Self discipline is when you do something that you know is right even though you don't want to do it. As a professional and safe pilot you have to maintain control over your desires & emotions. Have INTEGRITY and great WORK ETHIC and you'll succeed in life.
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