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Old 03-18-2023, 01:38 PM
  #8  
Eurowanderer
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Joined APC: Mar 2023
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Originally Posted by rickair7777 View Post
Correct. The PED FAR and matching federal law apply from block out to block in.

The sterile cockpit rule does not *specifically* address PED use but ANY PED use other than company tools like EFB apps is obviously a sterile violation because it's non-essential to flight ops. That's well established. So basically you can't do any photography in sterile, using any type of camera. You also cannot bring an analog type-writer and type up your term paper in sterile, etc.



Yes, this is one of the rabit holes I referred to. The problem is any regulatory action on the part of the FAA falls under admin law abd they have wide discretion to interpret intent. The NTSB almost always sides with the FAA. I can guarantee you that your penalties would be upheld. You might be able to appeal to the courts based on the FCC language, but that would be a long and expensive process, and you'd be out of work the whole time. And I kind of doubt you'd win.



The problem as I see it is that you are still "using" the device even if it requires no operator intervention. If it has wifi capability, you're probably hosed. People have gotten in trouble and fired for this, and I know one personally.

You might be able to get permission from the company to use a static film setup like that, one that you don't touch between block out and block in, but that's the only way I'd feel comfortable. And it would have to have no wireless functionality at all; the company cannot waive federal law. But another problem is your suction cup setup isn't certified by any regulatory agency not to say fall off and create a distraction or damage something in turbulence. I don't think you'd get approval.
Thanks very much for your detailed reply, I appreciate your efforts.

And yes I think it is better not to push up against some of these rules, fighting city hall just isnt worth it.

Its such a shame, the reults I have seen with very little effort can be rather impressive with modern 4K cameras and in reality can be obtained without any threat to flight safety.

Its a far cry from driving the old three holer with my Ricoh camera taking massively over exposed cockpit windows and under exposed cockpit interiors!

Thanks again.
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