User:KJ010110/PIVOT

In 2010, a sea change took place in regards to computing devices being used as Electronic Flight Bag (EFB) platforms. Expensive aircraft installed and dedicated “Class 2” EFB systems were suddenly being challenged by low-cost tablets – devices that were able to do virtually the same non-flight critical computational tasks but at a fraction of the cost.

The Apple iPad became the disruptive technology that changed the way both airlines and aviation regulators viewed portable EFB systems. The acceptance of the Apple iPad as a viable EFB platform was the primary cause for a dramatic uptick in the implementation of EFB program…especially in North America.

• File:Https://upload.wikimedia.org/wikipedia/commons/9/91/Generic tablet.jpg

With its superb design (human factors), low cost and flexibility, the iPad won scores of airlines and tens of thousands of pilots as customers. Soon thereafter Microsoft, Lenovo, Panasonic and a host of other tablet manufacturers entered into the EFB arena offering highly competitive devices to be used as portable EFB platforms.

When focusing on the EFB hardware, the demand from the airlines both then and now has been for the highest price/value combination for the platform…with cost being the most significant driver. The overall program must lower costs, have easy deployment processes and allow for fast, simplified approvals from their regulator.

Today, the widespread proliferation of numerous COTS tablet devices has created a significant demand for a way to securely contain/hold the EFB while allowing it to be utilized in all phases of flight. The solution has to be affordable and easy to deploy for virtually any airline operator. Up until recently, the options were limited to either a suction cup mount or a permanent mount structure physically attached to the aircraft by means of an STC. Unfortunately, both of these options have weaknesses.

Suction Cup Mounts These portable attachment devices remain a highly viable option for use in device retention and security and have been embraced by many operators. There are many reasons why an operator may elect to use a suction cup mount solution:

• It was gained both FAA and EASA regulatory approval as a portable mount.
• Wide variety of readily available options allows for rapid deployment opportunities.
• Low acquisition cost minimizes budgetary constraints.
• Until the long range EFB “end state” for implementations is known, it is a viable and easy-to-deploy solution.

However, in many areas of the world local aviation authorities have lost confidence in certain suction cup providers where design limitations have resulted in less than optimum reliability in all phases of flight. Additionally, the lack of standardization for installation locations has become an added concern as an improper placement could impact safety of flight. Clearly, another affordable alternative deployment solution is critically needed.

Permanent STC Mounts

Permanently installed EFB mounts overcome all of the obstacles that are encountered by suction cup mounts. Because they have achieved an STC, that certification means they have met all the required human factors testing and pose no adverse impact on aircraft operation. And because they have met all the requirements of the applicable DO-160 testing, questions regarding their reliability in all phases of flight in a non-issue.

However, along with the assurances that the mounts have as being certified parts, they also represent a potential significant increase in complexity and cost…both up-front and on-going:

• All installed parts must be accompanied with an FAA 8130-3 or EASA Form 1. This certification requirement can significantly impact the unit cost for each installation kit and also result in protracted order lead-time.
• The installation of each aircraft-attached mounting structure can only be done by licensed mechanics which adds soft-cost to the deployment.
• Aircraft out-of-service time can be anywhere from a few hours to days depending on the complexity of the installation process.
• Any change-out of the tablet devices may impact the STC and require a different installed part that is compatible with a new tablet which will again impact procurement cost, order lead time, installation time and maintenance costs.

And both suction cup and installed mounts also have another inherent fault - they both require that tablets be used without being enclosed in any kind of protective case. This presents airlines with another dilemma - if a tablet is dropped and broken as it is being placed into a mount…is the damage and the cost of the repair the responsibility of the pilot or the airline? And lastly, there can be on-going costs for installed solutions as some STC providers’ charge annual engineering or licensing fees for the use of their provided hardware. And for aircraft that are on lease, when they are being readied to be turned back, it is likely that a significant de-installation fee will be assessed by the STC holder. And then there is also the maintenance cost required to return the aircraft to its original pre-installed condition.

A New Idea

As a major North American airline was refreshing their EFB program, they engaged a group of pilots to contribute insights and thoughts on competitive EFB deployment hardware products being reviewed. One participant, Captain C. Michael Schulter, saw a significant weakness in most all of the EFB hardware options being considered. None provided a means to deploy and use a tablet in either an installed or portable mount without it first being removed from any protective case that was being used.

Captain Schulter decided to search-out a viable offering that could provide a protective case that could easily be attached to a mount so to enable the use of the protected tablet in all phases of flight. As no solution was found that met the need, Captain Schulter made the decision to build one. The result ended-up being the PIVOT case - an extremely robust, ventilated protective housing that contains a universal attachment clip which allows the case to be easily attached to virtually any mount structure that is deployed with the patented PIVOT attachment plate that mates to the clip. In the brief four years since its introduction, the PIVOT case has gained a tremendous following. It has been adopted as the Case-of-Choice by more than 50 leading commercial airlines around the globe. And with a failure rate of less than 0.1% - it is providing its customer untold savings by virtually eliminating tablet damage.  

A New Idea…One Step Further

While Captain Schulter’s success with the PIVOT case showed how it could be easily attached to mounts already being deployed…he still saw an unfilled gap - an affordable portable mount with robust installed mount-like capabilities but without the complexities of an STC.

Working with colleagues and industrial designers, a collaborative effort was made to create a formed metal plate that could be “snapped-into-place” on existing aircraft side window shrouds without the need to remove any of the existing clip boards and other parts. The structure was provisioned with a movable mount arm and was equipped with the PIVOT case attachment plate which allows easy slide-on/slide-off fitment of the PIVOT case. This integrated portable (installed without tools) case/mount solution provided increased durability and user functionality comparable or better than an installed mount at a cost that was closely aligned with suction cup solutions.

As a metal structure, this plate offered significant more rigidity and robust capabilities than a suction cup mount. And because it is placed in virtually the same location as STC-installed mounts - it provides virtually the same capability. The only difference…because it could be snapped-in-place without the use of any tools…it is totally “portable” solution.

Captain Schulter appropriately named the product “Long Term Removable Mount” (LTRM)…as that is exactly what it is. This revolutionary product line bridges the gap between entry level suction cup mounts and an installed STC mount and offers users an affordable best of both worlds solution.

• LTRM designs leverage available cockpit structures and material characteristics so to look and feel like they are a part of the aircraft.
• Each style is made to be manually affixed to the aircraft window without tools or hardware. PIVOT LTRM solutions overcome the business, economic, and operational challenges (or obstacles) posed by installed mounts or suction cups.
• LTRMs provide for a fully secure EFB device with a non-invasive, non-permanent base unit providing performance and reliability on par or better than typical installed STC mounts

FAA/EASA Approved

Each PIVOT LTRM fully adheres to the spirit and intent of the applicable guidance from the FAA and EASA governing regulations. While EASA AMC 20-25 has been in existence for many years, the FAA recently updated, clarified and simplified its general guidance to operators and to bring its document into closer alignment with AMC 20-25. One of the most significant changes in the latest version of AC120-76D is the elimination of “Classes” of EFB devices (Class 1, 2 and 3 are now either “portable” or “installed”). Additionally, this revised AC also reflects harmonization with International Civil Aviation Organization (ICAO).

In the context of the FAA AC, EFB equipment components supporting EFB applications are “installed” when they are incorporated into aircraft type design under 14 CFR part 21, or as a proper alteration under 14 CFR part 43, § 43.3. All other components supporting EFB functionality are considered “portable,” regardless of how often they are removed from the aircraft. A portable EFB is a portable EFB host platform, used on the flight deck, which is not part of the certified aircraft configuration. The PIVOT LTRM™ solutions meet or exceed all the defined regulatory criteria for use as Portable EFB Hardware Components supporting EFB applications.

Here, you can see how the FAA and EASA regulations have come together:

From FAA AC120-76D, Section 9.1.2 Portable EFB Hardware Components:

• Must be capable of being easily removed from or attached to their mounts by flightcrew member personnel without tools or maintenance action.
• Can be temporarily connected to an existing aircraft power port for battery recharging.

From EASA AMC 20-25, Section 5.1.1 Complementary Characteristics:

• If mounted, the portable EFB is easily removable from its mounting device or attached to it, without the use of tools by the flight crew. If mounted, the attachment or removal does not constitute a maintenance action.

Viewable Stowage

Stowage requires an inherent means to prevent unwanted EFB movement to prevent the device from jamming flight controls, damaging flight deck equipment, or injuring flight crew members should the device move about because of turbulence, maneuvering, or other action. EFB stowage is required for all portable EFBs not secured in or on a mounting device. Both the FAA AC and EASA AMC clearly details the means by which portable structures that are designed to secure a tablet EFB can be deployed as a “viewable stowage device”.

From FAA AC120-76D, Section 10.5.1 Viewable Stowage Devices and Components:

• A portable device or component used to secure portable EFB hardware, which is viewable to the pilot (e.g., kneeboards, suction cups, and removable trays). Viewable stowage solutions must not interfere with flight control movement, obstruct visual or physical access to controls and/or displays, or obstruct flight crew member ingress or egress. Viewable stowage should minimize blockage of the windshields to allow the pilots to maintain a clear view of critical outside references (e.g., during ground operations, taxiing, takeoff, approach, and landing). Training and procedures must address specific and acceptable placement of viewable stowage devices.

From EASA AMC 20-25, Section 4.19 Viewable Stowage:

• A device that is secured on the flight crew (e.g. kneeboard) or in/to an existing aircraft part (e.g. suction cups) with the intended function to hold charts or to hold acceptable light mass portable devices (for example an EFB of no more than 1 KG) viewable to the pilot at her/his required duty station. The device is not necessarily part of the certified aircraft configuration.

The design of the PIVOT LTRM™ structure meets the qualification as being a viewable stowage device as defined by FAA AC 120-76D and EASA AMC 20-25 as a portable component. Both the FAA and EASA allow for existing aircraft provisions to be employed while securing a containment device. The use of an existing aircraft provision assumes that no modification to the aircraft structure is made in order to accommodate the securing system and that the system can be put in place or removed without the use of tools and without any administrative control requirements.

PIVOT LTRM Solutions

Since the first prototype was made in 2017 for a B737-NG, aircraft specific LTRM mounts have been designed, manufactured and are being used today in virtually every type of commercial transport aircraft and are in-use by 30+ airlines around the globe.