Part.NCO, Electronic Charts and flights >FL80?

[ChickenHouse]

With August 25th and go-life of Part.NCO around the corner, yesterday an irritating question popped up at a local meeting regarding the use of electronic charts.

We were all happy to see GM1 NCO.GEN.135(b) state "The documents, manuals and information may be available in a form other than on printed paper. An electronic storage medium is acceptable if accessibility, usability and reliability can be assured." but, a fellow pilot pointed to us that this in reality is valid only for flights below FL80. Upon why, he argued with the approved environmental conditions for the operation of the usual portable devices. We looked at Apple tech specs and they set rule for operation of iPhone and iPad to be used up to an altitude of 8.000ft.

Will this rule out the use of tablets in flying high, so the usual non-pressurized IFR flight at FL120 cannot legally use electronic charts on i.e. iPads? So far, the devices did work in reality, bit what happens at a ramp check?

[dirkdj]

The Android tablet I use was perfectly fine at FL210, unpressurized. There is still the Garmin in the panel too.

[Jan Olieslagers]

One must fear the bit about "reliability assured" might spoil the game, given that the product documentation mentions the max. altitude.

This 8000' maximum is strange, though, it seems like a bit of C---r Y--r A--e ; I cannot imagine the certified products being especially protected against low barometric pressure. Surely if one (certified) bit of electronics can work (and work reliably) at a pressure altitude of, say, 12000', or even 20000', then they all can?

[nkt2000]

In the marine industry, electronic chart systems (ECDIS) have to be duplicated (two completely independent systems) in order to avoid having to carry paper charts as well. I presume this is what is meant by "Reliability assured" in the aviation context.

[ChickenHouse]

@JanO: yes, I agree, "reliability assured" may be the most crucial part with devices not approved in principal for operations at planned altitude. I have seen laptops and MP3 player fail at high altitude, but that was in the era of hard drives, so I guess that problem may be gone with flash/SSD drives now. One issue may still be reduced heat dissipation due to thin air, because I have seen several iPads fail hot&high. These devices are not sealed, or? 8000ft would be approximately 3/4 sea level pressure, but could higher differences cause errors and at which part of the device?

@nkt2000: redundant systems as in ECDIS will not serve as reliability relief, as the tablet is not approved at all for the environmental pressure by the vendor anyways.

What is your opinion, will it cause a problem upon ramp check, if I carry an iPad as paper chart replacement and filed a flight plan to go over the Alps? I am really undecided on that.

[bookworm]

The tech specs I've seen say 10,000 ft, but the point stands. I don't think you should read too much in to "reliability assured" in GM. If that is the most significant finding they come up with in a ramp check, you'll be doing better than most of us.

From a regulatory point of view this will only be an issue if you make it one.

[horizon flyer]

Perhaps strapping the Ipad to a Pelter effect cooling device as used in portable 12 volt picnic hampers may overcome the cooling problem. All the electronics is in the lid of mine and would be easy to modify. Can see a product opportunity, but current load is a bit high at 8amps. I can see the old cigar lighter socket melting at this load and no power left to run the Ipad.

[flybymike]

Only in the uk could we desperately seek a way to turn good news into bad.

[stevelup]

FAA gives blessing to iPad as electronic flight bag (https://www.flightglobal.com/news/articles/faa-gives-blessing-to-ipad-as-electronic-flight-bag-353898/)

FAA authorisation came after an intensive three-month in-flight evaluation, which included a successful rapid decompression test on the iPad to 51,000ft (15,550m) and non-interference testing. Executive Jet president Robert Garrymore says the firm was pleased to collaborate with Jeppesen and the FAA on the iPad EFB "and to support the introduction of this technology to the industry". Saying it has "an international focus", Jeppesen has already entered conversation with the European Safety Agency.

[ChickenHouse]

@stevelup: Yes, all recognized, but NetJets means pressurized cabin, so normal ops is not outside operational specs of the tablet and an emergency "non-standard" functional test does not cover what I was asking, unpressurized IFR GA flight?

[ChickenHouse]

Update, I talked to somebody doing ramp checks and he was quite clear on the issue. If he does a ramp check and on his "daily list of things to check" (did not know they have that up to now) he has "flight preparation", he has no issue with electronic charts for VFR flights and a recent moving map solution will be all fine. But, if he comes to know a planned IFR flight with planned altitude requiring the mandatory use of oxygen in a non-pressurized aircraft, their superior advised to "deny pass of check" (whatever this means). The argument is indeed NCO.GEN.135(b) statement reliability when an electronic device is operated outside of the vendor specification. There seems to be some discussion on that, but undecided yet. He also said inspectors don't like bad weather, so it would be unlikely to have a ramp check during IMC. I'll be always planning VFR.