Yoke Mounts & FAA?

[neilpilot]

The September 2016 issue of IFR "You Need an EFB" quotes AIM 1-1-17.b1.(c)(3) as indicating that a yoke-mounted holder is a "modification of the aircraft" governed by 14CFR Part 43, and recommends an A&P logbook entry.  My partner and I both fly behind an iPad, using a RAM yoke mount.  We've done this for years, have confirmed that the mount does not impede yoke movement, and neither of us find any issues in reading the panel or accessing switches or the fuel selector.

For those on Mooneyspacethat use use a yoke mount for an iPad, mini iPad, portable GPS or any other device - do you have an A&P signoff?  Have you had any discussion with an FAA inspector about your yoke mount?

I am not looking to debate the various means of mounting an iPad or the fact that a iPad mini is smaller than the standard iPad.  Just looking for information on if a yoke mount presents a verified regulator compliance issue.

[carusoam]

My portable GPS used to be on a ram mount.  It was removable in flight using a single hand knob.  No tools required.

does that help?

Best regards,

-a-

[neilpilot]

My RAM mount is also single-knob removable.  That does not help.  I'm looking for the following only:

Do you have an A&P signoff?  Have you had any discussion with an FAA inspector about your yoke mount?

[takair]

1 hour ago, neilpilot said:

Do you have an A&P signoff?  Have you had any discussion with an FAA inspector about your yoke mount?

Yes.  Have not had a direct discussion, but I have some reference material to justify the installation.  Our logbook entry says:  " Ȋnstalled Flight Enhancements Corp. tablet yoke mount in place of previously relocated clock. The mount is lighter weight than the clock which was removed and is installed consistent with AC20-173 and 43-13 and is considered a minor alteration."  I can send you a PDF with some more background, including the load test to justify.  Technically, anything installed in the aircraft should have a log entry, whether major or minor is usually the sticky part and varies from mechanic to mechanic and FSDO to FSDO.   Hope this helps.

[ArtVandelay]

It's a portable and not a modification of the aircraft.

[DonMuncy]

I saw this information in IFR, but have not been able to find AIM 1-1-17.b.1.(c)(3) to verify their statements. (Maybe I'm just not smart enough). I do not find anything in 14 CFR part 43 that addresses this issue.

IFR's statement is " AIM 1-1-17.b.1.(c)(3) informs us that  "modification of the aircraft, such as installing a panel mounted or yoke-mounted holder, is governed by 14 CFR part 43." (Italics are mine). I have always understood that mounting without the use of tools is different from panel mounting, and question their conclusion, until I am shown the published words myself. I am not infallible, and welcome someone enlightening me. Maybe a start would be to tell me where to find AIM 1-1-17.b.1.(c)(3)

[takair]

7 minutes ago, teejayevans said:

It's a portable and not a modification of the aircraft.

I tend to agree with regard to the RAM mount.  In my case, the mount is installed.

[DXB]

1 hour ago, neilpilot said:

For those on Mooneyspacethat use use a yoke mount for an iPad, mini iPad, portable GPS or any other device - do you have an A&P signoff?  Have you had any discussion with an FAA inspector about your yoke mount?

I am not looking to debate the various means of mounting an iPad or the fact that a iPad mini is smaller than the standard iPad.  Just looking for information on if a yoke mount presents a verified regulator compliance issue.

I do not have an A&P signoff for my Ram yoke mount. Nor will I be initiating any discussion with an FAA inspector on such legality issues, lest he/she gets any ideas.   Innate ambiguities in the regs give them means to bust just about anyone who motivates them to do so by pissing them off.  Like you, I would be curious to know if anyone has had any enforcement-oriented interaction with an FAA inspector on this or similar cockpit items, though it sounds unlikely to me.

When the inspector is coming up to my plane for a ramp check, maybe I'll distract them from my illegal ipad mount by turning on my dazzlingly bright LED paddle bulb position lights 

[neilpilot]

52 minutes ago, DonMuncy said:

I saw this information in IFR, but have not been able to find AIM 1-1-17.b.1.(c)(3) to verify their statements. (Maybe I'm just not smart enough). I do not find anything in 14 CFR part 43 that addresses this issue.

IFR's statement is " AIM 1-1-17.b.1.(c)(3) informs us that  "modification of the aircraft, such as installing a panel mounted or yoke-mounted holder, is governed by 14 CFR part 43." (Italics are mine). I have always understood that mounting without the use of tools is different from panel mounting, and question their conclusion, until I am shown the published words myself. I am not infallible, and welcome someone enlightening me. Maybe a start would be to tell me where to find AIM 1-1-17.b.1.(c)(3)

Well I can find it on page 1-1-17 of the current (May 2016) AIM.  It references handheld satellite GPS systems, so in legal terms it may not apply to an iPad mount.  Here it goes; read the last few lines:

(3) Antenna Location. The antenna location for GPS receivers used for IFR and VFR operations may differ. VFR antennae are typically placed for convenience more than performance, while IFR installations ensure a clear view is provided with the satellites. Antennae not providing a clear view have a greater opportunity to lose the satellite navigational signal. This is especially true in the case of hand−held GPS receivers. Typically, suction cups are used to place the GPS antennas on the inside of cockpit windows. While this method has great utility, the antenna location is limited to the cockpit or cabin which rarely provides a clear view of all available satellites. Consequently, signal losses may occur due to aircraft structure blocking satellite signals, causing a loss of navigation capability. These losses, coupled with a lack of RAIM capability, could present erroneous position and navigation information with no warning to the pilot. While the use of a hand−held GPS for VFR operations is not limited by regulation, modification of the aircraft, such as installing a panel− or yoke−mounted holder, is governed by 14 CFR Part 43. Consult with your mechanic to ensure compliance with the regulation and safe installation.

[RLCarter]

Not sure if this as any weight or not, several years ago when I was doing my Instrument Check Ride the DPE told me that the FAA only has an issue if the EFB is attached in any way to the aircraft, it has to be signed off. I did my check ride with my iPad laying in my lap to satisfy him, I asked if he wanted the Ram mount removed as well and he said that it wasn't holding anything electrical so it was fine. He also said that electrical means its own battery or ship power. He was an IA as well and offered to sign it off but I declined seeing how it was a rental.

[neilpilot]

Just now, RLCarter said:

Not sure if this as any weight or not, several years ago when I was doing my Instrument Check Ride the DPE told me that the FAA only has an issue if the EFB is attached in any way to the aircraft, it has to be signed off. I did my check ride with my iPad laying in my lap to satisfy him, I asked if he wanted the Ram mount removed as well and he said that it wasn't holding anything electrical so it was fine. He also said that electrical means its own battery or ship power. He was an IA as well and offered to sign it off but I declined seeing how it was a rental.

Good data point, but I'm surprised that the "electrical" matters.  If I understand this issue (and I'm obviously not sure that I do), it's not the iPad that's the issue, it's the mount being attached to the yoke.

[takair]

In my post above, I meant to say AC 20-173, Installation of Electronic Flight Bag Components.  Note that there is a distinction in advice on part 23 and 25 aircraft.  

[neilpilot]

Just now, takair said:

In my post above, I meant to say AC 20-173, Installation of Electronic Flight Bag Components.  Note that there is a distinction in advice on part 23 and 25 aircraft.  

Thanks Rob, but I had already read AC 20-173.  I found it not specific enough to answer my question.  Also this AC is clearly advisory; I'm looking for regulatory input to determine if I have an issue I need to address.

[Cruiser]

I think the requirement for A/P sign off on the yoke mount comes from those installations that do not fully remove the cradle from the yoke. There is a bracket that clamps on and remains on the yoke when the cradle/iPad is removed. 

According to "some" FAA and A/P individuals, this bracket is a "permanent" alteration to the plane and needs the appropriate sign-off. To others it is fly specs in pepper issue. You can decide for yourself. 

[carusoam]

Seems like a legal opinion weighs more than any PP opinion can...

They seem to be restating the reasons why portable mount GPSs are not valid for primary navigation.  They make great back-up devices.

They spend a few sentences regarding the antennae not being in view of the full constellation of satellites and there is no RAIM function for testing the GPSs accuracy.

These are critical functions of a panel mount IFR GPS.  Having them, is what gives you confidence to perform an approach to land in IMC minimums.  Not having them is still good for backing up your primary navigation equipment.  In VMC, the Mark I eyeball is still king!

To find the airman's information manual (AIM), look to wherever the FARs are printed, including electronically...  I have a copy automatically updated in my WingX documents section...

DM, your thoughts?

Best regards,

-a-

[neilpilot]

I know that you can't always trust Google search results, but this leads me to believe that the operator of the aircraft can determine if a yoke mount is OK without an A&P signoff:

https://www.faasafety.gov/spans/noticeView.aspx?nid=4155

[carusoam]

The clear issues seem to be...

1) mechanical interference of anything the pilot attaches to the yoke.  Holder, iPad, GPS or anything including paper charts.

2) electrical noise that may interfere with the GPS antenna.  Having an antenna close to the GPS is an increase of noise for the weak signal.

3) blocked signals by having the antenna inside the cockpit.

4) Not having a RAIM test. (Accuracy) 

PP thoughts based on reading the above, not a mechanic or an aviation attorney....

Best regards,

-a-

[takair]

Lots of stuff here:. http://www.paperlesscockpit.com/guidance/efb/

[DonMuncy]

26 minutes ago, neilpilot said:

Well I can find it on page 1-1-17 of the current (May 2016) AIM.  It references handheld satellite GPS systems, so in legal terms it may not apply to an iPad mount.  Here it goes; read the last few lines:

(3) Antenna Location. The antenna location for GPS receivers used for IFR and VFR operations may differ. VFR antennae are typically placed for convenience more than performance, while IFR installations ensure a clear view is provided with the satellites. Antennae not providing a clear view have a greater opportunity to lose the satellite navigational signal. This is especially true in the case of hand−held GPS receivers. Typically, suction cups are used to place the GPS antennas on the inside of cockpit windows. While this method has great utility, the antenna location is limited to the cockpit or cabin which rarely provides a clear view of all available satellites. Consequently, signal losses may occur due to aircraft structure blocking satellite signals, causing a loss of navigation capability. These losses, coupled with a lack of RAIM capability, could present erroneous position and navigation information with no warning to the pilot. While the use of a hand−held GPS for VFR operations is not limited by regulation, modification of the aircraft, such as installing a panel− or yoke−mounted holder, is governed by 14 CFR Part 43. Consult with your mechanic to ensure compliance with the regulation and safe installation.

Thanks. I told you might not be smart enough. In my defense, my AIM is old and the numbering is different.

The next step would be to find out what Part 43 says about "yoke mounting of things". I just gave it a cursory glance and didn't find anything that seemed to apply. I still yield to those with more expertise.

[neilpilot]

Just now, takair said:

Lots of stuff here:. http://www.paperlesscockpit.com/guidance/efb/

I like the FAA advisory (see line I my last post) much better.  They conclude that  "EFB yoke mounts must be STC'd ".  Can you show me a mount that's STC'd?

[takair]

18 minutes ago, neilpilot said:

I like the FAA advisory (see line I my last post) much better.  They conclude that  "EFB yoke mounts must be STC'd ".  Can you show me a mount that's STC'd?

That is why I mentioned differences between part 23 and part 25, but I should have been more specific.  Note that they specifically leave out part 23.  By omission, I read it to mean that an STC is not required for part 23.  Much of this is left to interpretation. 

Some considerations in the yoke mount.....installed or temporary are:. Head impact....what happens to YOU if you crash, security.....what does IT do in a crash, interference.....does it interfere physically or visually with anything, and dynamics.....what does the weight do to the controls.  On part 27 and 29 helos, this can have serious consequence.  In part 25 they worry more about the head impact implications.  Part 23 , these things are not regulated to the same level, nor do we reach the same level of safety.  Ultimately the paperwork just provides assurance of meeting a safety objective.  Who is willing to sign off on it comes down to who is willing to accept that liability or verify that there is minimal liability.  In part 23, we can retain responsibility as pilots or we can ask our mechanic to sign.  If the mechanic is not comfortable, they can call in the FAA.  The FAA FSDO can then field approve or defer it to the ACO.  On and on.  That said, I would hope that at some point the FAA would call foul and issue a letter of clarification or opinion.  I have yet to find one on this subject....ultimately I suspect that is what might close out the question.

[JasonW]

Just more info.  I did my IFR check ride Jan. 3rd 2016 with an iPad mini on the yoke as my charts.  No issue with the examiner.  

On a less factual basis, what is the difference with the yoke mount paper chart clips that have been used for many, many years?

[carusoam]

Air worthiness is based on the yokes being un impeded..., not weighed down or obstructing views or crashing into panel instruments...

a paper chart and a clip is probably outside the original aw testing.

GPS and iPads have gotten much larger and heavier than the clip and paper.

Realistically, pulling many Gs, my hands can control the weight of several iPads, compared to how much strength it takes to control a Mooney with a trim failure....

fortunately, in this case the PIC is still in control of the ship with it's iPad.

The FAA has done a good job of having us talk about what we can potentially  goof up.  

There will have to be a very large discussion if the world has to move away from yoke mounted portable devices.  They are too right to be wrong.

Best regards,

-a-

[Andy95W]

The interpretation I've received from 2 different FSDOs is that if it takes tools to remove, it is no longer portable.  From FAR 43:

--------------------------------

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information: 

(1) A description (or reference to data acceptable to the Administrator) of work performed. 

(2) The date of completion of the work performed. 

(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.

-----------------------------

The A&P that signs off on it decides it's airworthiness, since it is only a minor alteration.

Therefore, if you have a yoke clamp GPS mount with a cigarette lighter power cord, no logbook entry.  The owner/operator is responsible for ensuring the airworthiness.

If you use a bolt-on type RAM ball and connect to the avionics bus, you will need a simple l ogbook entry with an A&P signature saying that the mount and electrical connections are airworthy.

 

 

[kortopates]

My understanding of this is exactly the same as N1395W. As long as you keep it a portable installation which means no tools are required and it's not tied into the ships power then you are golden. But if you go with a mount that required tools to install then you'd better have the required approval and sign off. Ditto if it's is tapped into ships power. That's the only point where it becomes controversial as to whether it falls under a minor or major alteration but most will fall under a minor alteration requiring only a log book entry. I think the key point from this discussion is that you should make sure not to use an iPad mount that requires tools to install and thus will be considered an installed device requiring proper approvals.

I am very happy with my "portable" mount installation.

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