AIN Blog: FAA Should Sign Off On Mobile Device Own-ship Display

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WingX Pro 7
What pilot would not want to be able to see his position clearly shown on a chart with nearby terrain highlighted? WingX Pro 7 on an iPad mini.
December 19, 2013 - 7:01pm

The FAA’s refusal to acknowledge reality rears its ugly head in Advisory Circular 120-76B, Guidelines for the Certification, Airworthiness, and Operational Use of Portable Electronic Flight Bags. In this AC, the FAA—in a standalone bold-type note, warns users of portable devices that display charts and moving maps that “Class 1 or Class 2 EFBs must not display own-ship position while in flight.”

In other words, the FAA, in its infinite wisdom, does not want you to use an Apple iPad or Android device with moving-map software and the computer’s internal or an external GPS receiver to verify your aircraft’s position. If, for example, you are flying near the edge of Class B airspace without a clearance into that airspace, the FAA would rather that you avoid that airspace boundary using a chart and the view of the ground to fix your position. Or, if you can’t see the ground, then perhaps a slightly more accurate VOR cross-check, if that’s the only navigation equipment available. Preferably, of course, your airplane has its own certified and accurate Waas-capable GPS receiver and a built-in certified moving-map, but not all aircraft are so equipped.

Never mind the fact that the uncertified GPS-driven moving map on the iPad is far more accurate than many navigation sources. The FAA’s feeling is that if pilots were to rely on the iPad’s or an external uncertified GPS, they would be straying into special-use airspace (SUA) all the time.

This is backwards thinking.

First of all, ever since iPad moving maps began using GPS to show own-ship position, pilots have been using them to navigate and to avoid SUA. There is a high probability that devices such as these have prevented many cases of improper SUA penetration.

Second, the UK’s own air traffic control service providers, Nats, as far back as 2009, endorsed the use of a portable non-certified GPS device to help pilots avoid SUA. Nats and Airbox Aerospace collaborated on the original Aware airspace alerting and positional awareness device, and now that functionality is offered in an iPad/iPhone app.

When the Aware system was launched in 2009, Nats director of safety Gretchen Burrett said, “Infringements into controlled airspace are a serious safety concern for private and commercial pilots. In the complex airspace over the UK, it is imperative that all aircraft respect airspace boundaries so we can all share the sky safely. By keeping pilots conscious of nearby airspace boundaries as they fly, Aware helps pilots to steer clear of accidental infringements. Nats is proud to have been involved with this project, which we believe will be a major asset for airspace safety.”

U.S. pilots, especially those flying business jets and using iPads, worry that they will be penalized if they are caught using own-ship position information on their mobile devices. And in fact, all the moving-map iPad apps now have a software switch to turn off own-ship position display. This seems to be something that iPad app developers inserted as a means of gaining approval for use in airline and charter company cockpits. Some pilots carefully turn off own-ship display after landing.

AC 120-76B is an advisory circular and hence only advisory in nature. ACs are not regulatory, although they may reference regulations. In the case of own-ship position display, it seems that while the FAA recommends against use of this excellent feature, there is no regulation prohibiting its use (unless part of a commercial operators’ OpSpecs). Of course, own-ship display on a non-certified device should be used with caution and as a backup to other more precise techniques. But, because there is no regulation that tells pilots what they can use to determine their position when lacking any technological system besides their Mark 1 eyeballs, then there is no reason why an iPad app with a suitable GPS source can’t aid that purpose.

Can you think of any controlled-flight-into-terrain accidents when an iPad with own-ship and also terrain/obstacle display might not have helped the pilots?

The FAA needs to get real and maybe even consult with the folks at Nats. Own-ship display on non-certified devices is here to stay, pilots of all stripes are using it and such a display offers a clear and compelling safety benefit.

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matt
on December 19, 2013 - 12:04pm

Another example of what's wrong with the FAA. Maybe someone in congress will introduce another bill dealing with this issue as has been done with the third class medical and the sleep apnea issues. The person or persons who approved this policy need to be fired or moved to an area of government where they can not do any further "harm".

Jean Luc Lessard's picture
Jean Luc Lessard
on December 19, 2013 - 1:49pm

The purpose behind the FAA’s disallowance of using ships own position and similar features in tablet based EFB’s is directly tied to the hardware limitations associated with the quality and fidelity of the embedded and accessory GPS sensors, NOT a question of pilot complacency.  We all can recall what happened when MFD's and the like were introduced into the cockpit - lots and lots of lost lives by CFIT as pilots were distracted by those new, beautiful screens!  As evidenced by the multitude of DOT/FAA/DoD and industry testing of embedded cell assisted GPS and uncertified external GPS accessories, these sensors cannot be relied upon in the same way that aircraft systems and sensors perform.  There are no consumer product standards applied to the design of these components, which guarantee minimum Design Assurance Levels (DAL) to aerospace industry acceptable, and CAA approved, standards such as RTCA/DO-178B.  Further, these products are victim to airborne and aircraft configuration environmental disruptions, which emanate from aircraft transmitters, insulators and thermal elements (e.g. window heating elements for example), acoustic dampeners and powerplant operating resonate frequencies.

In the case of external consumer grade equipment electronically “tethered” via RF mediums such as Bluetooth LE and NFR, these frequencies have been demonstrated to adversely affect aircraft systems, including but not limited to the reception and transmission of GPS L1 band transmissions, especially in some older system designs which are already in wide service and operation.  Many of these intentional and unintentional radiators and other environmental realities make the use of non-certified equipment not only impractical, but can more directly present inconsistent data to pilots from aircraft nav data presented in the basic “T” or in more modern PFD/ND displays.  Authorizing the use of equipage with known and repeatable hazardous effect, regardless of public feedback, is not only reckless, but directly in contrast to the FAA’s charter to uphold the most stringent levels of safety in our national and international airspace responsibilities.  There use is especially shortsighted in light of the fact that the FAA has approved installed equipment, which make the use of onboard systems and sensors within tablet applications such as Jeppesen, Foreflight, LIDO, Wing X Pro 7, etc..  These equipment meet the industry DAL and, and in the case of Apple and FAA Approved flyTab Class 2 EFB system for iPad, have been issued TSO standards in evidence of its exceptional performance and operational pedigree.   

I understand that Private and ATP pilots desire portable low-cost options, so do airlines and other for-hire operators.  The reality is that systems like the flyTab one I mentioned are very inexpensive for our industry, often less than a full load of fuel for a complete dual installed system.  At those price points, to supplant safety in the absence of what equates to modest financial means is foolhardy and irresponsible.  As the saying goes, if the driver cannot affort to fill the RV, don’t start driving it (take it from me I once opted to pay for the gas when I went on vacatino with a friend who had an RV!)  The same theory of economics applies to GA and, well, as the general public are best served by the FAA’s awareness of the limitations and hazards associated with the use of non-qualified sensors, then I’d say public interest is best served – which is something you can’t say everyday about the government! 

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