Real Answers from Real Pilots

360° view in ERJ-145

This is something that found on YouTube, its a 360° view of a erj 145 take off and landing, If you can watch it with a VR headset it is awesome! If not you can use a laptop and scroll around.

The nerd in me was stoked to see the video. The pilot side of me is wondering how a group of Envoy pilots made this and still have jobs.

Tory

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Probably a repositioning, beginning shows part 91 with Envoy approve.

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Interesting thing here, airlines never actually dispatch under part 91. They can dispatch under part 91 rules, but they are actually still dispatched under 121 regulations.

Furthermore, FAA regulations specifically prohibit pilots from using portable electronic devices when operating under part 91 as well.

This video, while interesting, is really inappropriate and these pilots are playing with fire.

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I see where they said they had permission from Envoy, I still would not have done it. Permission from Envoy is very different than permission from the FAA.

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Chris,

Can you elaborate about where it says in 91.21 that pilots are prohibited from using portable electronic devices when operating under part 91?

91.21(b)(5) states that 91.21(a) doesn’t apply to any other portable electronic device that the operator of the aircraft has determined will not cause interference with the navigation or communication system of the aircraft on which it is to be used. In this situation I’m not sure if PIC or the air carrier certificate holder is deemed the operator (clarification here would be great!), but it seems that it would be legal as the operator has made that determination-whether PIC or Envoy?

Obviously in any situation the PIC must use good and legal ADM as to the events and command of their aircraft, and a good amount of pilots would deem this an unnecessary risk. However, I just wanted to look for that clarification if there is something that I am interpreting incorrectly.

Thanks!

Justin,

Envoy is the operator. I think it is safe to say that if the camera doesn’t have a part number or a TSO certification Envoy can’t make the claim that they have determined that the electronic device will not cause interference.

Devices aside, airlines also have PR guidelines that restrict crew members from publishing content while in uniform with logos and badges visible unless the crew members have received authorization for producing and publishing the content while representing the company.

Tory

Tory,

Thanks for the follow up. I didn’t think about the TSO aspect as it hasn’t become a part of my career yet, but always something to think about. Is that part if the “dispatched under 91 rules but 121 regulations” comment Chris alluded to?

As for the PR guidelines, it seemed as if that is a non-issue in this case as there was approval from Envoy.

Justin

That is true for any electronic device in the flight deck.

Call me a crusty Captain, but I can not speculate and I’m baffled as to why people are defending him without proof. For the record I am not accusing him. I just made a comment about my own skepticism. I can only hope he has gone through appropriate processes.

Tory

Tory,

Do you mean flight deck on a 121 aircraft, or “flight deck” on any aircraft.

I’m not defending either, if that’s the way its coming across. I love having these conversations with those more knowledgeable and experienced in other settings so I can have the same conversations with my students.

Appreciate the input!

From two friends at Envoy, rumor has it his videos are screened by Envoy and he may be receiving compensation for each video.

And to answer your question I meant 121, but 91 has regs too as Chris mentioned. I just read the regs as is and I’ve never bothered to find out what it would really require to do it.

Even if Envoy is allowing it, doesn’t mean you should nor does it mean that you are protected.

Tory

Justin,

The “operator” of an aircraft is the air carrier, regardless of which part it is dispatched under. From the FAA " Operate. With respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise)."

As to 91.21(b)(5), upon further review, you are right, I do not see where it specifically bans the use of electronic devices. I still maintain that it is a huge risk though and should not be done. not to mention the fact that ALPA has spent years fighting against having cameras added to the cockpits, then these knuckleheads go out, record themselves and ut it all over Youtube.

I would still make the case though that when an airliner is dispatched under part 91 it is done so to take advantage of certain other rules, it is not just cart blanche to ignore the airline’s FOM or all part 121 rules.

Chris

Chris,

Thanks for the reply and clarification/answer of the questions asked. I’m always eager to learn and ensure I have the correct informatIon for my students, as well as others interpretations of the regulations. I’ve had many conversations with other instructors regarding various regulations, and appreciate the opportunity to grow and learn.

As an instructor working to instill good habits in my students, as well as me working towards a long and safe career in aviation, I agree that some risks aren’t necessary. Even an incident completely unrelated to electronics in the flight deck can become a greater headache or worse when other questionable situations are present.

Thanks!

I guess I didn’t even think about the FAA having a problem with them making the video, i follow him on youtube and he hasn’t said anything about the FAA getting involved. In any case it was an interesting video, even though as Chris said probably wasn’t the best idea.
Gabe

It was an interesting video. Frankly, I think it is nice for people to be able to see what they are signing up for when considering this career.

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