A REPORT FROM THE 

PORTABLE ELECTRONIC DEVICES 

AVIATION RULEMAKING COMMITTEE 

TO THE FEDERAL AVIATION ADMINISTRATION 

 Recommendations on Expanding the Use of Portable Electronic Devices During Flight 

September 30, 2013 

Prepared for: 

Associate Administrator for Aviation Safety 

Federal Aviation Administration 

Washington, DC 

 
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TABLE OF CONTENTS

LETTER TO ASSOCIATE ADMINISTRATOR FOR AVIATION SAFETY ........................... vii

EXECUTIVE SUMMARY ........................................................................................................... ix

Definition ................................................................................................................................ ix 

Methodology ........................................................................................................................... ix 

Current Regulatory Framework ............................................................................................... x 

Notice of Policy and Request for Comments .......................................................................... x 

Constituency Descriptions ...................................................................................................... xi 

Recommendations .................................................................................................................. xi 

Conclusion ............................................................................................................................. xx 

1.0 PORTABLE ELECTRONIC DEVICES AVIATION RULEMAKING COMMITTEE ... 1

2.0 BACKGROUND ................................................................................................................ 2

2.1 Overview ....................................................................................................................... 2

2.2 Scope ............................................................................................................................. 3

2.3 Methodology ................................................................................................................. 6

2.4 Subcommittees .............................................................................................................. 8

2.5 Working Groups............................................................................................................ 9

3.0 CURRENT REGULATORY FRAMEWORK ................................................................. 11

3.1 Regulatory History ...................................................................................................... 12

3.2 Associated Regulations and Security Activity ............................................................ 12

3.3 Operational Allowance ............................................................................................... 13

3.4 FCC Regulations ......................................................................................................... 13

4.0 NOTICE OF POLICY AND REQUEST FOR COMMENTS ......................................... 15

4.1 Federal Register Notice ............................................................................................... 15

4.2 Assessment of Federal Register Comments ................................................................ 15
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5.0 CONSTITUENCY DESCRIPTIONS ............................................................................... 17

5.1 PED Manufacturers and Distributors .......................................................................... 18

5.2 Pilot and Flight Attendant Groups .............................................................................. 18

5.3 Aircraft Operators ....................................................................................................... 18

5.4 Passenger Experience Associations ............................................................................ 18

5.5 Airplane and Avionics Manufacturers ........................................................................ 18

5.6 Federal Aviation Administration ................................................................................ 19

5.7 Other U.S. and International Regulatory Authorities ................................................. 19

6.0 THRESHOLD RECOMMENDATIONS ......................................................................... 20

6.1 SMS Methodology ...................................................................................................... 20

6.2 Harmonization............................................................................................................. 22

6.3 Standardization ........................................................................................................... 22

7.0 TECHNICAL RECOMMENDATIONS .......................................................................... 23

7.1 Airplane Certification Requirements for New Airplanes ........................................... 23

7.2 Airplane Certification Requirements for Airplanes Currently in Production ............. 24

7.3 Enabling Airplane Operators to Permit Expanded Passenger PED Use ..................... 24

7.4 Coordination with the FCC ......................................................................................... 34

8.0 OPERATIONAL RECOMMENDATIONS ..................................................................... 34

8.1 Stowage of PEDs ........................................................................................................ 34

8.2 Airline Personnel Training .......................................................................................... 35

8.3 Creation of a Job Aid for Operators ............................................................................ 36

8.4 Regulatory Action ....................................................................................................... 36

9.0 SAFETY COMMUNICATIONS RECOMMENDATIONS ............................................ 37

9.1 PED Terminology ....................................................................................................... 37

9.2 Communication Regarding PED Usage Policies ........................................................ 38

10.0 CONCLUSION ................................................................................................................. 40
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EXECUTIVE SUMMARY

On January 7, 2013, the Administrator of the Federal Aviation Administration (FAA) established 

the Portable Electronic Devices (PED) Aviation Rulemaking Committee (ARC) in order to 

provide a forum for the U.S. aviation community and PED manufacturers to review the 

comments received from the Notice of Policy/Request for Comments regarding PED policy and 

guidance published in the Federal Register. The ARC was tasked to make recommendations to 

further clarify and provide guidance on allowing additional PED usage without compromising 

the continued safe operation of the aircraft.1 Under the Charter, the ARC was scheduled to 

terminate on July 31, 2013. At the request of the members, the FAA extended the ARC Charter 

until October 31, 2013.2

 The ARC has completed its review, and this report provides the results 

and its recommendation to the FAA. 

Definition		

In formulating its recommendations, the ARC developed and used the following definition of 

PED, which applies to all of the recommendations and supporting information included in this 

report: 

Portable Electronic Device: A Portable Electronic Device (PED) is any piece of 

lightweight, electrically-powered equipment. These devices are typically consumer 

electronics devices functionally capable of communications, data processing and/or 

utility.3

Methodology

The ARC identified sources and methods for collecting objective data through presentations 

from subject matter experts (SMEs) and review of data submitted by the FAA, other federal 

agencies including the Federal Communications Commission (FCC), industry associations, and 

ARC members. The ARC also reviewed current guidance material and information on PEDs, 

including documents promulgated by the FAA, Radio Technical Commission for Aeronautics 

(RTCA), and FCC. 

Identification of Key Issues 

The ARC used the public comments received in response to the Federal Register notice 

to develop a list of key issues, which was used to assist the members in developing a 

roadmap for decision making. The key issues were tasked to individual subcommittees 

for further discussion. In using the key issues model, the members were asked to 

determine the relative priority of the issue, as well as the applicable subject area 

(technical, operational, or safety communications) for discussion. 

                                                            

1 Appendix C, FAA Aviation Rulemaking Committee Charter: Portable Electronic Device Aviation Rulemaking 

Committee (Effective Date: 01/07/13) at ¶3. See also, 77 FR 53159 (August 31, 2012). 2

 Appendix C, FAA Aviation Rulemaking Committee Charter (Renewal): Portable Electronic Device Aviation 

Rulemaking Committee (Effective Date: 08/28/2013) at ¶3 (describing two additional Committee tasks). 3

 For clarity, the ARC notes that the definition of PEDs is intended to encompass transmitting PEDs (T-PED). 
A Report from the PED ARC to the FAA

Executive Summary Page x 

Subcommittees & Working Groups 

The ARC was tasked to focus on the technical, operational, and safety aspects of 

expanding PED usage on aircraft that are within the FAA’s purview to address. In order 

to distribute the workload and provide the members an opportunity to debate issues in 

smaller groups, three subcommittees were each assigned key issues addressing these 

aspects of PED usage for consideration. The ARC recommendations submitted in this 

report were initially developed through the subcommittee process. 

During the extension granted under the renewed Charter, the ARC requested the 

assistance of the FAA in forming two working groups (“Tiger Teams”) to develop the 

safety risk assessment and a standardized PED stowage policy. The Safety Assessment 

and Stowage Standardization Working Groups were comprised of ARC members, as well 

as industry and FAA SMEs, and each working group was tasked to address an area of 

study and develop additional information for inclusion in this report. 

Current Regulatory Framework

Under the current regulatory environment, the operator is still responsible for determining which 

PEDs may be used on its airplanes. Each operator’s PED policy determines what types of devices 

may be used during which phase(s) of flight. Crewmembers are responsible for ensuring 

passenger compliance with an airplane operator’s PED policy. Current guidance allows broad use 

of non-transmitting PEDs during non-critical phases of flight without detailed study of specific 

PEDs. However, if an operator wishes to expand its PED use allowance, FAA policy and 

guidance is in place to allow PED use, with the proper testing and analysis, during any phase of 

flight. Operators have been hesitant to deviate from current FAA guidance, as there has been no 

clear direction on methods to demonstrate an equivalent level of safety when expanding PED use 

into critical phases of flight. 

FCC regulations also govern certain aspects of PED usage. The FCC has established rules for 

radio transmitters and consumer electronics to minimize the risk of harmful interference to other 

users of the airwaves. FCC rules, with a few notable exceptions, do not prohibit use of radio 

transmitters or consumer electronics aboard airplanes. 

Notice of Policy and Request for Comments

On August 31, 2012, the FAA published a Notice of Policy, Request for Comment regarding 

Passenger Use of Portable Electronic Devices on board Aircraft in the Federal Register.

4

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FAA sought comments on current policy, guidance, and procedures that aircraft operators use 

when determining if passenger use of PEDs may be allowed during any phase of flight on their 

aircraft. The comment period closed on October 30, 2012, and resulted in 162 formal 

submissions, 854 separate commenters, and a total of 1,062 discrete comments. 

The PED ARC members reviewed the compiled comments and discussed the comments by each 

question category. From each category, specific key issues were identified and used to guide the 

discussion, narrow the issues presented, and formulate the ARC’s recommendations. 

                                                            

4

 77 FR 53159 (Docket No. FAA-2012-0752). 
A Report from the PED ARC to the FAA

Executive Summary Page xi 

Constituency Descriptions

In order to achieve a balance between the regulator, regulated parties, other industry 

stakeholders, and the flying public, the FAA selected ARC members across a broad spectrum of 

constituencies. ARC membership encompassed the following constituent groups representing 

stakeholders involved in all aspects of the PED use debate: 

• PED Manufacturers and Distributors 

• Pilot and Flight Attendant Groups 

• Aircraft Operators 

• Passenger Experience Associations 

• Airplane and Avionics Manufacturers 

• Federal Aviation Administration 

• Other U.S. and International Regulatory Authorities including the Federal 

Communications Commission (FCC) and Transportation Security Administration (TSA) 

In addition, the ARC invited supplementary participation by FAA and other federal and 

international regulatory authorities to support the members’ efforts as they collected information 

and data and debated recommendations. 

Recommendations

The ARC sets forth a total of 29 recommendations on the expanded use of PEDs, including 

threshold recommendations, as well as recommendations addressing the technical, operational, 

and safety communications aspects of PED usage. The ARC members reached consensus on all 

of the recommendations with the exception of one aspect of Recommendation #10, as discussed 

below. 

In creating a decision making framework for debating recommendations regarding the safe 

expansion of PED usage in flight, the ARC focused on an approach that lowers the risk of 

potential PED interference to an acceptable level. 
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A Report from the PED ARC to the FAA

Executive Summary Page xiii 

The ARC developed two recommendations for enabling airplane operators (under 14 

CFR Parts 91K, 121, and 135) to permit expanded passenger PED use to all phases of 

flight. (See Recommendations #9 & #10 below.) Five members of the ARC dissented to 

the Method 2 allowance as set forth in Recommendation #10, and their dissent position is 

included in this report. 

In addressing technical issues, the ARC also noted the role of the FCC in addition to the 

FAA and recommended coordination between the agencies. (See Recommendation #11 

below.) 

Operational Recommendations 

In addressing operational aspects of PED usage, the ARC discussed concerns raised by 

passengers about the differences between operators’ polices and made recommendations 

regarding communication of and standardization among PED stowage policies. (See 

Recommendations #12 – #14 below.) 

The members discussed the importance of training for airline personnel and developed 

recommendations to facilitate better awareness among flight and cabin crews with the 

expansion of PED use in flight. (See Recommendations #15 – #17 below.) 

In addition, the ARC also proposed a standardized job aid to facilitate operator 

implementation of expanded PED usage policies. (See Recommendation #18 below.) 

The operational recommendations also address the importance of the FAA’s role in 

providing guidance that will allow operators to pursue expanded PED usage policies. 

(See Recommendations #19 & #20 below.) 

Safety Communications Recommendations 

In the past, PEDs that transmitted or received radio frequency energy were a small subset 

of the larger population of PEDs. However, the consumer electronics market has evolved 

to where the majority of PEDs incorporate at least one, and frequently more than one, 

radio technology used for communication and data networking. The ARC has generated 

several recommendations that take into consideration the evolving marketplace for these 

devices. (See Recommendations #21 – #25 below.) 

The ARC also emphasized the importance of effective communication with passengers, 

the public, and the aviation industry regarding PED policies and developed 

recommendations designed to work toward that goal. (See Recommendations #26 – #29 

below.) 
A Report from the PED ARC to the FAA

Executive Summary Page xiv 

Summary of Recommendations 

The ARC recommendations appear below, including a cross-reference to the detailed 

discussion in this final report: 

Recommendation Recommendation

Area

Final Report

Reference

Recommendation #1—The ARC recommends that the FAA 

conduct an SMS risk assessment and engage safety experts on its 

staff and across industry to look for hazards associated with PED 

interference potential. While the PED ARC membership included 

some system expertise to identify hazards, it is suggested that a more 

focused group could develop a complete list of hazards that should 

be risk assessed to SMS standards. To support the expanded use 

recommendations proposed by the ARC, the members further 

recommend a safety risk assessment, as outlined in Appendix F of 

this report. 

Threshold 6.1 

Recommendation #2—The ARC recommends that the FAA 

promote harmonized policy with international regulatory authorities, 

including EASA, such that the recommendations made in the ARC 

report are universally accepted by international regulatory 

authorities. The ARC encourages the FAA to use the International 

Air Transport Association (IATA) and the International Civil 

Aviation Organization (ICAO) as forums to promote expanded PED 

usage policy within the recommended safety framework. 

Threshold 6.2 

Recommendation #3—The ARC recommends that the FAA 

standardize the travelling experience for consumers such that they 

come to expect a consistent approach from air carriers regarding 

PED usage and stowage requirements. 

Threshold 6.3 

Recommendation #4―New Type Certificate Applications: The 

ARC recommends that the FAA require PED tolerant (i.e., RTCA 

DO-307 certified) airplane designs for all new type certificates 

issued for airplanes under 14 CFR Part 23 (commuter category only) 

or Part 25. 

Technical 7.1 

Recommendation #5―New Derivative Certificate Applications: 

The ARC recommends that the FAA require PED tolerant (i.e., 

RTCA DO-307 certified) airplane designs for all new derivative 

certificates issued for airplanes under 14 CFR Part 23 (commuter 

category only) or Part 25. 

Technical 7.1 
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Recommendation #6—New Avionics, Major Changes in Type 

Designs: The ARC recommends that the FAA require new avionics 

system(s) installations that are considered major changes in type 

design (Supplemental Type Certificate [STC] or Amended Type 

Certificate [ATC]) with catastrophic failure classifications 

demonstrate PED tolerance (i.e., RTCA DO-307 certification) for 

those systems when certificated on airplanes under 14 CFR Part 23 

(commuter category only) or Part 25. For new avionics system(s) 

installations that are considered major changes in type design (STC 

or ATC), where the systems are required by operating part or with 

major or hazardous failure classifications, and cannot demonstrate 

PED tolerance, a safety risk assessment (as discussed in 

Recommendation #10 below) must be accomplished for those 

systems. 

Technical 7.1 

Recommendation #7―The ARC recommends that associated FAA 

guidance documents, including AC 20-164 and AC 91-21.1B, be 

evaluated to incorporate alternative approach(es) to allow 

certification of individual systems for PED tolerance. Suggested 

revisions may also include changes to RTCA DO-294 guidance 

applicable to 14 CFR Part 119 certificate holders and considerations 

for the operating environment.

Technical 7.1 

Recommendation #8―Newly Manufactured Airplanes: The 

ARC recommends that the FAA implement operational regulations 

that require all newly manufactured airplanes, which will be 

operated by 14 CFR Part 119 certificate holders under 14 CFR Parts 

121 or 125, to be shown to be PED tolerant (i.e., RTCA DO-307 

certified). This requirement would also apply to avionics system(s) 

installations that are considered major changes in type design (STC 

or Amended Type Certificate [ATC]) with catastrophic failure 

classifications, or equipment required by operating part, incorporate 

PED tolerant (i.e., RTCA DO-307 certification) designs when 

certificated on airplanes under 14 CFR Part 23 (commuter category 

only) or Part 25. 

For avionics system(s) installations that are considered major 

changes in type design (STC or ATC), where the systems are 

required by operating part or with major or hazardous failure 

classifications, and cannot demonstrate PED tolerance, a safety risk 

assessment (as discussed in Recommendation #10) must be 

accomplished for those systems. 

These regulations should have a compliance date no later than 

December 31, 2015. The FAA should grant petitions for limited 

extensions for operators introducing aircraft with extenuating 

circumstances, when justified. 

Technical 7.2 
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Reference

Recommendation #9―The ARC recommends that the FAA modify 

AC 91-21.1B (and any associated guidance) to provide processes by 

which operators can demonstrate compliance with 14 CFR Section 

121.306, 125.204, or 135.144, as applicable, in order to allow 

expanded use of PEDs to all phases of flight. Consideration 

should be given to maintaining cabin safety requirements (e.g. 

attention to safety announcements) when expanding PED 

usage.

Technical 7.3 

Recommendation #10—The ARC recommends that in revising AC 

91-21.1B (and any associated guidance), the FAA adopt the 

following methodology for expanding PED usage by passengers to 

all phases of flight. In particular, the FAA should immediately 

amend/revise current regulatory guidance documents to provide a 

methodology by which operators can permit PED usage by 

passengers during all phases of flight, using one of the following two 

methods: 

Method 1. The operator may perform PED tolerance testing, or 

the operator may document evidence of testing by an airplane 

manufacturer or other entity, that demonstrates airplanes are 

PED-tolerant in accordance with Sections 3 and 4 of RTCA DO307. 

Method 2. The operator may validate that its airplane and 

operations meet the requirements and limitations of the safety 

risk assessment proposed by the ARC for adoption by the FAA 

(attached as Appendix F to this report) for the phases of flight 

(identified as Phases 1-8 in Figure 2 below) in which the 

operator wants to allow expanded passenger PED use. The 

ARC’s proposed FAA safety risk assessment addresses both 

back door and front door effects. Mitigations are supported by 

flight experience, analysis, and test data, and are provided for all 

failure condition classifications of Major and above, as well as 

for equipment required by operational rule. Back door effects 

are assumed to be covered by an airplane’s HIRF certification of 

critical systems. If an airplane is not HIRF-certified, or has not 

had other back door interference testing completed, additional 

analysis and systems testing may be required. 

Note: Five members of the ARC dissented to the Method 2 

allowance discussed above in Recommendation #10, and their 

dissent position is included in this report. (See Recommendation 

#10—Dissent Position below.) 

Technical 7.3 

Recommendation #11―The ARC recommends that the FAA 

consult with the FCC with regard to Title 47 CFR parts that apply to 

airborne use of PEDs. 

Technical 7.4 
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Recommendation #12―The ARC recommends that the FAA and 

industry stakeholders develop standard content and timing for cabin 

and flight deck crewmember instructions to passengers on use and 

stowage of PEDs. The development process should include testing 

of the messaging with members of the traveling public. 

Operational 8.1 

Recommendation #13―The ARC recommends that to support 

standardized industry best practices for stowage related to PEDs, the 

FAA update stowage policy and guidance documents to incorporate 

expanded use of PEDs as necessary. 

Operational 8.1 

Recommendation #14―The ARC recommends that the FAA work 

with industry to develop a methodology by which exceptions can be 

granted to PED stowage requirements for passengers with special 

needs (so that they may use devices with adaptive or assistive 

technologies) without compromising safety. 

Operational 8.1 

Recommendation #15―The ARC recommends that the FAA work 

with industry stakeholders to develop consistent and standardized 

training on the identification of PED interference effects so that 

flight crews are better able to mitigate risks to aviation safety and 

report possible incidents for further investigation as necessary. 

Operational 8.2 

Recommendation #16―The ARC recommends that the FAA work 

with industry stakeholders to develop standardized processes for 

detecting/observing, reporting, evaluating, centralized data storing 

using existing systems if available, and summarizing of incidents, if 

any, involving adverse Electromagnetic Interference (EMI) effects 

on equipment, as well as passenger noncompliance with PED usage 

or stowage restrictions. Use of these tools should be part of 

enhanced employee training as proposed by the ARC. 

Operational 8.2 

Recommendation #17―The ARC recommends that the FAA work 

with industry stakeholders to develop model frameworks for training 

programs targeting crewmembers and other affected operator 

personnel (including management), with minor but necessary 

variations owing to fleet size, airplane configurations and regulatory 

basis (i.e., part 135 vs. 121, etc.) utilizing standardized statements. 

This effort should involve initial and recurrent training for all 

employees, including cabin and flight deck crew, gate agents, and 

other customer service/contact personnel. 

Operational 8.2 

Recommendation #18―The ARC recommends that the FAA work 

with industry stakeholders to develop a detailed job aid to lead an 

operator through key items of consideration. This job aid should be 

incorporated in the applicable FAA guidance documents. 

Operational 8.3 
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Reference

Recommendation #19―The ARC recommends that the FAA 

provide operators with policy guidance that institutes the approaches 

set up in the ARC for expansion of use as acceptable methods for 

compliance with PED use regulations. 

Operational 8.4 

Recommendation #20―The ARC recommends that the FAA 

establish policy guidance for flight crew expectations. This policy 

should clearly define standardized roles and responsibilities for 

flight crews in the context of expanded PED usage allowance by the 

operator. These expectations should lessen the crew’s role in 

enforcing the PED usage policy. 

Operational 8.4 

Recommendation #21―The ARC recommends that the 

terminology in FAA PED regulations, including 14 CFR 91.21, 

121.306, 125.204, and 135.144, be updated to remove the outdated 

references to electronic devices. This terminology update should 

also be applied to all future policy and guidance documents.

Safety 

Communications 9.1 

Recommendation #22―The ARC recommends the FAA consider 

(and encourage operators to consider) using only the term PED 

when communicating information on operator policy to the public. 

Based on market data from CEA, most PEDs carried by passengers 

today incorporate one or more modes of wireless connectivity. With 

that in mind, distinguishing PEDs as Transmitting or NonTransmitting may be confusing to the general public. 

Safety 

Communications 9.1 

Recommendation #23―The ARC recommends that the 

FAA promote and encourage airplane operators to establish 

more stringent policy and guidance for PEDs that are not 

easily accessible to passengers or crewmembers during 

flight operation. Guidelines to PED manufacturers on the 

test requirements, satisfactory test data, and operational 

characteristics of these devices should be published in order 

to provide operators with an appropriate means to evaluate 

PEDs for use. Examples of these devices include, but are 

not limited to, some medical devices; asset tracking devices; 

data collection and monitoring devices; and devices for 

inventory management. (See Appendix E.) 

Safety 

Communications 9.1 
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Reference

Recommendation #24―The ARC recommends that the FAA 

promote and encourage airplane operators to develop a common 

device terminology (e.g., e-readers, smart phones, and tablet 

computers) when communicating to passengers about expanded 

usage policies. The ARC further recommends implementation of 

this recommendation be completed by November 30, 2013 to 

minimize confusion for the traveling public and allow the operator 

to clearly state which types of PEDs are allowed to be used onboard 

their airplanes and during which phase(s) of flight as outlined in the 

operator’s usage policy. 

Safety 

Communications 9.1 

Recommendation #25―The ARC recommends that the FAA 

encourage airplane operators to provide to passengers lists of PEDs 

that may not be operated inflight, and make such information easily 

accessible through various media including printed material, 

websites, and audio or visual safety information. 

Safety 

Communications 9.1 

Recommendation #26―The ARC recommends that the FAA and 

other stakeholders work together to develop messaging designed to 

better inform the public regarding why there would be restrictions 

on use of PEDs. 

Safety 

Communications 9.2 

Recommendation #27―The ARC recommends that regulators, 

industry representatives and members of the public collaborate on 

the development of standardized information for travelers, which 

will be available in multiple, pre-tested formats at ticket purchase, in 

seat-pocket magazines, as well as distributed through various mass 

media outlets. 

Safety 

Communications 9.2 

Recommendation #28―The ARC recommends that the FAA, in 

collaboration with the airline industry, explain to the public why 

there is a difference in PED usage policy for crewmembers versus 

passengers. 

Safety 

Communications 9.2 

Recommendation #29―The ARC recommends that such 

collaborative efforts include programs designed to ensure the 

validity and efficacy of public messaging, using appropriate 

research, development, testing, evaluation, and feedback processes. 

In addition to the typical methods used for messaging to passengers 

(e.g., crewmember announcements, website and kiosk pop-ups, 

inflight magazines), the ARC further recommends that public 

information campaigns also leverage social media resources and 

applications to better anticipate and manage public perception and 

behavior, as well as counter misinformation as necessary. 

Safety 

Communications 9.2 

   
A Report from the PED ARC to the FAA

Executive Summary Page xx 

Conclusion

The ARC completed its tasking and prepared this report in accordance with its mandate to make 

recommendations to further clarify and provide guidance on allowing additional PED usage 

without compromising the continued safe operation of airplanes. In prioritizing its 

recommendations, the ARC noted that certain threshold recommendations were essential to 

establishing the initial framework and operating environment in which expanded PED usage 

could be implemented. The ARC organized the remaining recommendations around its tasking 

to address the technical, operational, and safety communications aspects associated with the 

expansion of passenger PED usage to all phases of flight. The ARC designed its 

recommendations to allow for phased implementation consistent with stakeholder capabilities, as 

well as sufficient opportunity to engage in a public education campaign concurrent with 

publication of updated/revised guidance and the allowance for expanded PED usage. 
A Report from the Portable Electronic Devices Aviation Rulemaking Committee

to the Federal Aviation Administration

Recommendations on Expanding the Use of Portable Electronic Devices During Flight 

 Page 1 

1.0		 PORTABLE ELECTRONIC DEVICES AVIATION RULEMAKING COMMITTEE

In August 2012, the Federal Aviation Administration (FAA) published a Notice of 

Policy/Request for Comments on current policy, guidance, and procedures that aircraft operators 

(ranging from pilots of general aviation aircraft to operators) use when determining if passenger 

use of portable electronic devices (PEDs) may be allowed during any phase of flight on their 

aircraft.5 The FAA also sought comments about other technical challenges for addressing the 

problems associated with determining if and when PEDs can be used. In the Notice, the FAA 

indicated the desired outcome of the Request for Comments was to have sufficient information to 

allow operators to better assess whether more widespread use of PEDs during flight is 

appropriate, while maintaining the highest levels of safety to passengers and aircraft. 

The FAA noted its intent to establish an Aviation Rulemaking Committee (ARC) to review the 

comments submitted and provide recommendations that might permit the more widespread use 

of PEDs. The FAA acknowledged the Federal Communications Commission (FCC) as a key 

partner in the FAA/industry collaboration to explore broader use of PEDs during flight. 

The PED ARC provided a forum for the U.S. aviation community and PED manufacturers to 

review the comments received from the Federal Register Notice.6

 The PED ARC made 

recommendations to further clarify and provide guidance on allowing additional PEDs without 

compromising the continued safe operation of the aircraft. This report includes the ARC’s 

recommendations for allowing additional PED usage on airplanes. 

The PED ARC membership included representatives from the FAA as well as members 

representing various stakeholder interests including PED manufacturers and distributors, pilot 

and flight attendant groups, aircraft operators, passenger experience associations, and aircraft and 

avionics manufacturers. The names of all ARC members, FAA participants and subject matter 

experts (SMEs), and other U.S. and international regulatory authorities are listed in Appendix A. 

Under the Charter, the ARC was scheduled to terminate on July 31, 2013.7 At the request of the 

members, the FAA extended the ARC Charter until October 31, 2013.8

 The ARC has completed 

its review, and this report provides the results and its recommendation to the FAA. 

                                                            

5

 77 FR 53159 (August 31, 2012). 

6 PED ARC Charter at ¶3. See also, 77 FR 53159. 7 PED ARC Charter at ¶10.

8 See Letter Re: Request for Extension Portable Electronic Devices Aviation Rulemaking Committee (ARC) from K. 

Thornburg, Co-Chair, to M. Huerta, FAA Administrator, dated July 12, 2013. See also, PED ARC Charter 

(Renewed) at ¶3. 
A Report from the PED ARC to the FAA

 Page 2 

2.0		 BACKGROUND

This chapter discusses background information relevant to the ARC’s methodology and the 

development of its recommendations. 

2.1 Overview 

The PED ARC was established to provide a forum for the aviation community and PED 

manufacturers to review the 162 submissions (which included 1,062 discrete comments) received 

in response to the Federal Register Notice of Policy/Request for Comments.9 The ARC’s main 

objective was to make recommendations to the FAA Administrator through the Associate 

Administrator for Aviation Safety (AVS-1) to further clarify and provide guidance on allowing 

additional PEDs without compromising the continued safe operation of the aircraft.10 The ARC 

was tasked to focus on the technical, operational, and safety aspects of expanding PED usage on 

aircraft that are within the FAA’s purview to address. 

In 1966, the FAA first published regulations to address the issue regarding the use of PEDs on 

aircraft.11 The rulemaking was prompted after the 1958-1961 studies of PED interference 

concluded that portable frequency modulation (FM) radio receivers caused interference to 

navigation systems such as VHF Omni Range (VOR) navigation systems. The rulemaking 

concluded that the aircraft operator was best suited to determine which PEDs would not cause 

interference with the navigation or communication system on their aircraft. The rulemaking 

effort acknowledged the impracticality of requiring the FAA to conduct or verify tests of every 

conceivable PED, as an alternative to a determination made by the operator. 

The potential for aircraft interference depends on the aircraft and its electrical and electronic 

systems, as well as the type of PED being used. Prior to fly-by-wire flight controls, the primary 

concern was the susceptibility of sensitive aircraft communication and navigation radio receivers 

to spurious radio frequency emissions from PEDs. Many of these aircraft using this older 

technology are still in service, and may be as susceptible today to interference as they were 45 

years ago. When aircraft included fly-by-wire controls and electronic displays, the susceptibility 

of these aircraft systems also became a concern. Today's highly critical fly-by-wire controls and 

electronic displays are designed and certified to withstand interference from various radiated 

fields, including transmitting PEDs. However, not all aircraft electrical and electronic systems 

were designed to withstand these fields. These newer aircraft still have sensitive navigation, 

communication, and surveillance radio receivers that may be susceptible at certain frequencies to 

spurious radio frequency emissions from PEDs. Indeed, in some areas of the world, aerial 

navigation is conducted using ground-based radio navigational aids, such as VOR/DME, which 

may be as prone to interference as they were in the 1960s. Other ground-based navigational aids 

used for precision approaches, such as ILS, may also be at risk. PEDs have changed considerably 

in the past few decades and output a wide variety of signals. Some devices do not transmit or 

receive any signals, but generate unintentional low-power radio frequency emissions. Other 

PEDs, such as e-readers, are only active in this manner during the short time that a page is being 

                                                            

9

 PED ARC Charter at ¶3. See also, 77 FR 53159. 10 PED ARC Charter at ¶3. 

11 See generally, PED ARC Charter at ¶2, Background. 
A Report from the PED ARC to the FAA

 Page 3 

changed. Of greater concern are intentional transmissions from PEDs. Most PEDs have Internet 

connectivity that includes transmitting and receiving signals wirelessly using radio waves, such 

as Wi-Fi, Bluetooth, and commercial mobile band technologies. These devices transmit higher 

powered emissions and can generate spurious signals at undesired frequencies, particularly if the 

device is damaged. 

Since the initial rulemaking, the FAA has led four industry activities to study PEDs as the 

devices have evolved. In the early 1990s, the variety of PEDs had grown to the point that the 

industry had concerns about keeping up with the technology. The third industry effort was 

launched to review the overall risk of PED use. Those findings indicated that the probability of 

interference to installed aircraft systems from PEDs, singly or in multiples, is low at this time. 

However, the possibility of interference to aircraft navigation and information systems during 

critical phases of flight, e.g., takeoff and landing, should be viewed as potentially hazardous and 

an unacceptable risk for aircraft involved in passenger-carrying operations. Therefore, the Radio 

Technical Commission for Aeronautics (RTCA) recommended that the use of PEDs be restricted 

during certain critical phases of flight.12

The FAA agreed and developed Advisory Circular (AC) 91-21.1B, which outlined this guidance 

as an acceptable method of compliance for PED regulations.13 The guidance in AC 91-21.1B is 

still in use and serves as the basis for most operators' current policy allowing broad use of nontransmitting PEDs above 10,000 feet. 

2.2 Scope 

The ARC developed a definition of PED to provide context for the discussion and frame the 

recommendations included in this report. In discussing the scope of its tasking, the ARC also 

wanted to address certain discussions on topics related to the PEDs-on-aircraft debate but 

otherwise determined to be outside the scope of its tasking. 

2.2.1 Definition of PED 

In formulating its recommendations, the ARC developed and used the following 

definition of PED, which applies to all of the recommendations and supporting 

information included in this report: 

Portable Electronic Device: 

A Portable Electronic Device (PED) is any piece of lightweight, 

electrically-powered equipment. These devices are typically consumer 

electronics devices functionally capable of communications, data 

processing and/or utility.14

                                                            

12 RTCA DO-233, page 1, paragraph 5, prepared by SC-177, ©1996. 

13 FAA AC 91-21.1B, Use of Portable Electronic Devices Aboard Aircraft (8/25/06). 

14 For clarity, the ARC notes that the definition of PEDs is intended to encompass transmitting PEDs (T-PEDs). 
A Report from the PED ARC to the FAA

 Page 4 

Examples of PEDs include, but are not limited to, the following 

commonly manufactured devices: laptop computers; personal 

communication devices such as hand-held smart phones, tablet computers, 

media players, e-readers, and personal digital assistants; gaming and 

entertainment devices; medical and other healthcare assistive devices such 

as pacemakers and hearing aids; asset trackers; data collection and 

monitoring devices; inventory management and point-of-sale devices; 

wearable computers and other devices that may or may not incorporate 

wireless transmitters and receivers. 

2.2.2 Issues Outside of Scope Considered/Discussed 

The PED ARC discussed a number of issues in determining the scope of its 

recommendations. During the discussions, questions were raised as to the scope of the 

ARC Charter. As issues arose, the Designated Federal Official (DFO) coordinated 

guidance for the members on the FAA’s tasking. In developing the recommendations in 

this report, the members noted two additional issues of concern—voice communication 

and malicious use of PEDs. While both issues were outside the defined scope of the 

ARC’s tasking under its Charter, the members felt strongly that these issues need to be 

addressed. 

With member consensus, the ARC believed it represented the constituencies needed to 

provide the FAA with recommendations surrounding the use of voice communication on 

airplanes. In the Federal Register Notice, the FAA invited comment on passenger 

perspectives on the use of PEDs specifically, "Should voice communications using other 

technologies such as voice over IP be limited or restricted"?15 While the FAA’s intent 

may have been a review of the technical issues associated with voice communications, 

most of the respondents that commented referred in general to voice communications and 

provided a social argument whether it should be allowed or not. The PED ARC has been 

exposed to several surveys about voice communication in general. The results of the 

domestic surveys were consistent with the Federal Register commenters where 69 

percent of the respondents did not desire cell phone usage (interpreted by the ARC to 

mean cell phone voice calls).16 

The ARC has identified PED passenger compliance and onboard security events as being 

issues that should also be addressed in the context of the voice communication question. 

Voice communication in the small, confined space of an airplane cabin may become a 

concern when crewmembers are distracted from their other onboard duties by incidents 

involving interpersonal friction between two or more passengers. 

                                                            

15 77 FR 53159, 53162. 

16 An international survey, which included passenger responses regarding such services, resulted in 68% acceptance 

of onboard phone service.. 
A Report from the PED ARC to the FAA

 Page 5 

As the voice communication issue is prevalent in the media, Congress, and in daily 

passenger operations, the ARC members felt these constituencies are expecting voice 

communication to be dealt with in concert with the PED ARC’s tasking. Some members 

felt they could not go back to their constituencies ignoring this important part of the 

overall PED usage issue on airplanes. To document the member inputs, positions, and 

issues, the PED ARC has included these discussions in this report but has not made 

recommendations with regard to the voice communication issue. The members 

encourage the FAA to review the voice communication issue as discussed and consider 

whether actions should be taken when adopting or implementing the recommendations 

from the PED ARC. 

Finally, there is one FCC regulation that prohibits cellular phones operating in the 800 

MHz band from operating aboard airplanes in flight.17 While the ARC understands its 

tasking is specific to issues the FAA can regulate (or promulgate guidance on), the 

current FCC rule can create confusion because modern cell phones operate in many other 

frequency bands and also contain other types of transmitters such as Wi-Fi and Bluetooth. 

The ARC recognizes that the FAA and FCC have different responsibilities. However, the 

members have asked the FAA to consult with the FCC with regard to Title 47 regulations 

that apply to airborne use of PEDs. (See Recommendation #11 below.) 

With regard to questions surrounding malicious use of PEDs, ARC members were 

assured that this issue is being addressed by other governmental agencies in additional to 

remaining outside of the scope of the ARC. The ARC received briefings from the 

Department of Homeland Security (DHS), the FAA Office of Infrastructure Protection, 

and the FAA Aviation Special Operations & Security Division. Current and active 

Federal Government and private industry structure(s) in place for the appropriate 

disposition of these concerns include, but are not limited to:18

• Homeland Security Act of 2002, Section 871 (6 U.S.C. 451) 

• Presidential Policy Directive (PPD) 21, Critical Infrastructure, Security and 

Resilience 

• Homeland Security Presidential Directive 16, Aviation Security Policy 

• Domestic Outreach Plan, National Strategy for Aviation Security 

• National Infrastructure Protection Plan (NIPP) 

• Transportation Systems Sector Government Coordinating Council (TSSGCC) 

                                                            

17 47 CFR 22.295. 

18 Presidential Policy Directive (PPD) 21, Critical Infrastructure Security and Resilience, February 12, 2013, 

identified 16 critical infrastructure sectors and designated the Department of Homeland Security (DHS) and DOT as 

the co-Sector Specific Agencies (SSA) of the Transportation Systems Sector (TSS). The Transportation Systems 

Sector Government Coordinating Council (TSSGCC) establishes sub-sector councils (aviation, highway, freight rail, 

mass transit, maritime and pipeline). TSSGCC membership consists of key Federal departments and agencies 

responsible for or involved in aviation security. The Aviation Government Coordinated Council (ASCC). The 

Critical Infrastructure Partnership Advisory Council (CIPAC) provides the operational mechanism for carrying out 

the sector partnership structure. CIPAC provides the framework for aircraft owner and operator members of ASCC 

and members of AGCC to engage in intra-government and public-private cooperation, information sharing, and 

engagement across the entire range of critical infrastructure protection activities.
A Report from the PED ARC to the FAA

 Page 6 

2.2.3 Special Use Monitoring 

In the public comments, the ARC noted at least one illustration of a case when a special 

needs passenger may require the use of a PED to enable communication or therapy. 

With the advancement in technology, the industry has developed applications for tablets, 

smartphones, and other PEDs to assist passengers with special needs. The FAA received 

several comments from the public describing one particular use of these devices by 

passengers with autism. These devices can be used to help these passengers 

communicate or provide other types of support. 

While the ARC understands and appreciates these concerns, the devices being used are 

still consumer off-the-shelf devices that present the same risks discussed in this report. 

The ARC notes that expansion of use of these devices for special needs must meet the 

same criteria for allowance of use of all other PEDs. 

2.3 Methodology 

The ARC identified multiple sources and methods for collecting objective data including 

presentations from subject matter experts (SMEs), as well as review of data submitted by the 

FAA, other federal agencies, industry associations, and ARC members. 

2.3.1 Meetings 

The ARC met six times and held twelve teleconferences. The meeting/teleconference 

schedule is included below. 

Face-to-Face Meetings were held: 

• January l5 ‒ 17, 2013, in Washington DC 

• February 26 ‒ 28, 2013, in Washington DC 

• April 23 ‒ 25, 2013, in Washington DC 

• June 4 ‒ 6, 2013, in Washington DC 

• July 9 ‒ 11, 2013, in Washington DC 

• September 24 ‒ 25, 2013, in Washington DC 

Teleconferences were held: 

• January 31, 2013 

• February 14, 2013 

• March 14, 2013 

• April 18, 2013 

• May 16, 2013 

• May 30, 2013 

• June 13, 2013 

• June 20, 2013 

• June 27, 2013 
A Report from the PED ARC to the FAA

 Page 7 

• July 18, 2013 

• July 25, 2013 

• August 29, 2013 

Members also received multiple logistical briefings on the Freedom of Information Act 

(FOIA) and guidance on how to respond to media inquiries regarding the work of the 

ARC during the pendency of its debate and discussions. 

Finally, the Administrator and senior FAA officials from across the Agency also 

addressed the ARC in support of its efforts to find a path forward on expanding the use of 

PEDs during flight while maintaining the highest levels of safety. 

2.3.2 Data Collection 

Since the PED ARC had a diverse membership across multiple sectors of the aviation 

industry, as well as PED manufacturer representation, the members sought information 

and data from a variety of sources. The ARC received a number of informational 

briefings in its efforts to develop the recommendations contained in this report. 

The members received briefings on the following topics from the FAA: 

• Congressional Study on Cell Phone Use on Aircraft19 

• Safety Management System (SMS) Philosophy, Guidance and Methodology 

• RTCA DO-307 PED Tolerance Testing Procedures 

• Electronic Flight Bag Use and Certification Guidelines 

• Current PED Stowage/Use Policy and Survey of Cabin Inspectors 

The members also received briefings on the following topics from other U.S. regulatory 

authorities and industry organizations: 

• FCC Management of the Radio Spectrum and Radio Frequency (RF) Devices 

• FCC Provisions for Wireless Medical Devices 

• Cell Phone Use Survey Data (provided by members) 

• Current Airplane PED Tolerant Design Status 

• Consumer Research on PED Usage on Aircraft 

• Use of DO-307 Process for Designing to T-PED Tolerance 

• PED Interference Data Summaries (provided by members) 

                                                            

19 See 77 FR 54651 (September 5, 2012). 
A Report from the PED ARC to the FAA

 Page 8 

2.3.3 Informational Review 

During its review of the issues related to PED usage, the ARC reviewed current guidance 

and information on PEDs, including: 

• Current regulations and FAA guidance documents related to PEDs and operational 

allowance for PED usage by passengers 

• SMS/Safety Risk Management (SRM) Decision making Methodology 

• RTCA documents related to certification of aircraft/systems as PED-tolerant 

2.3.4 Identification of Key Issues 

The ARC used the public comments received in response to the Federal Register Notice 

to develop a list of key issues, which was used to assist the members in developing a 

roadmap for decision making. The key issues were tasked to individual subcommittees 

(described below) for further discussion. In using the key issues model, the members 

were asked to determine the relative priority of the issue as well as the applicable subject 

area (technical, operational, or safety communications) for discussion. 

2.4 Subcommittees 

The ARC formed three separate subcommittees to review the key issues raised in the ARC 

review of docket and member comments on the expansion of PED usage in flight. The key 

issues fell into technical, operational, and safety communications categories, and thus three 

subcommittees were each assigned the applicable group of key issues. The Subcommittee Chairs 

(as identified in Appendix A) were appointed to research each issue and propose potential 

recommendations to the plenary committee for consideration. Separating the key issues into 

three areas helped distribute the workload among the members and provided a forum for ARC 

members to debate issues in smaller groups aiding the overall ability to reach group consensus. 

The Subcommittee Chairs called in SMEs to provide additional information when needed. 

2.4.1 Technical Subcommittee 

The Technical Subcommittee focused on key issues surrounding airplane tolerance to 

PEDs, as well as PED power and transmission standards. The subcommittee used 

technical site visits to various system experts to gain knowledge to help disposition the 

key issues assigned. The subcommittee navigated across aviation, telecommunications, 

and PED industry design standards to form recommendations that met the expectations of 

each stakeholder group. This subcommittee provided initial recommendations, as the 

Operational and Safety Communications subcommittees needed direction on the 

technical path for expanded PED usage to be clarified as they debated key operational 

and safety communications recommendations. 
A Report from the PED ARC to the FAA

 Page 9 

2.4.2 Operational Subcommittee 

The Operational Subcommittee focused on key issues surrounding the onboard 

management of PED device usage, crew communications, and the desire for standardized 

practices across operators. The subcommittee used member expertise in cabin and 

cockpit operations, PED device operation, and passenger adherence to current PED usage 

policies to inform its discussions. The subcommittee balanced the needs of a safe 

operational environment with the passengers’ desire for connectivity for both 

entertainment and business functions. This subcommittee ensured that recommendations 

could be implemented across the spectrum of airplane operators, regardless of size or 

type of fleet. There were many types of operators represented on the subcommittee, 

including: general aviation, business jet, and scheduled and charter transport. 

2.4.3 Safety Communications Subcommittee 

The Safety Communications Subcommittee played a key role in addressing passenger 

desires and need for information within the ARC’s recommendations. This 

subcommittee ensured that a series of technical and operational procedures would not be 

conceived without understanding the passengers’ need for awareness, understanding, and 

ability to comply. This subcommittee was assigned key issues regarding boarding/preflight announcements, coordinated communications, understanding of PED operational 

modes, and how best to communicate to passengers (and the public) the potential 

interference risk to critical airplane systems. 

2.5 Working Groups 

As the conclusion of the initial charter period approached, the ARC worked to develop a 

recommended path for operators to expand PED usage in flight. The members believed that two 

areas required further assessment prior to finalizing the ARC’s recommendations. Before 

accepting that the recommended path could be reliably implemented by operators, the ARC 

requested an extension of the initial PED ARC Charter and identified two additional work 

tasks.20 During the extension granted under the renewed Charter, the ARC requested the 

assistance of the FAA in forming two Working Groups (Tiger Teams) to develop the safety risk 

assessment and a standardized PED stowage policy. The Working Groups were comprised of 

ARC members as well as industry and FAA SMEs, and each Working Group was tasked to 

address an area of study and develop additional information for inclusion in this report. 

2.5.1 Safety Assessment Working Group 

The PED ARC membership was concerned that operators needed more specific guidance 

on how to complete an adequate safety risk assessment when expanding PED use; 

particularly with regard to its effects to critical safety systems. Information from the 

FAA and aircraft manufacturers with respect to failure effect classification would be 

useful for the operator to determine effective mitigation. To support the use of a Safety 

                                                            

20 PED ARC Charter (Renewed) at ¶3 (describing two additional Committee tasks). 
A Report from the PED ARC to the FAA

 Page 10 

Risk Assessment tool in expanding PED usage, the ARC members desired to review the 

work product of such a working group. 

To support the members’ request, the Safety Assessment Working Group comprised of 

PED ARC members, as well as industry and FAA SMEs was formed. This working 

group developed and documented an avionics system functional hazard risk assessment, 

which is included as Appendix F to this report. 

2.5.2 Stowage Standardization Working Group 

The PED ARC membership received briefings from the FAA on current PED stowage 

policy and guidance material, as well as actual operator PED stowage policy examples. 

The ARC membership was concerned that insufficient guidance exists in this area such 

that (1) operator stowage policy could negate an intended expanded passenger PED use 

policy if an uninformed view of projectile and egress risk from PEDs exists; and (2) 

passengers would be confused by conflicting stowage policies across the operator 

community. 

The members noted that a recommended interim PED stowage policy guidance document 

would be of use to operators while the FAA considers action on Recommendation #13 in 

this report. The Stowage Standardization Working Group, consisting of informed PED 

ARC members as well as industry and FAA SMEs, developed the PED stowage policy 

assessment and considerations included in Appendix G of this report. 
A Report from the PED ARC to the FAA

 Page 11 

3.0 CURRENT REGULATORY FRAMEWORK

This chapter provides a discussion of the current regulatory framework applicable to 

airplane/equipment certification processes and operational allowance procedures in relation to the 

use of PEDs during flight. 

Under the current regulatory environment, the operator is still responsible for determining which 

PEDs may be used on its airplanes. Each operator’s PED policy determines what types of devices 

may be used during which phase(s) of flight. Crewmembers are responsible for ensuring 

passenger compliance with that airplane operator's PED policy. Typically, when a flight attendant 

observes a violation, he or she may request that the passenger turn off and stow the device. If the 

passenger remains non-compliant, depending on the operator's policies and procedures, the flight 

attendant may report the violator to the flight deck for a decision on whether to hold or divert the 

flight, and/or notify law enforcement.21 

Current guidance allows broad use of non-transmitting PEDs during non-critical phases of flight 

without a detailed study of specific PEDs.22 However, if an operator wishes to expand its PED 

use allowance, FAA policy and guidance is in place to allow expanded PED use, with the proper 

testing and analysis, during any phase of flight. 

Title 14 of the Code of Federal Regulations (14 CFR) §§ 91.21, 121.306, 125.204, and 135.144 

establish the regulatory requirements for use of PEDs without the authorization of the airplane 

operator. These regulations are set up to prevent persons from using PEDs on civil airplanes 

unless the operator (or in the case of general aviation operators, the pilot) has determined that the 

device will not cause interference to the communication and navigation systems on the airplane. 

There are four specific devices that have been excluded from this requirement and they are listed 

below in 14 CFR 91.21 (cited as an example). 

§ 91.21 Portable electronic devices. 

(a) Except as provided in paragraph (b) of this section, no person may operate, nor may any operator or pilot in 

command of an aircraft allow the operation of, any portable electronic device on any of the following U.S.-

registered civil aircraft: 

(1) Aircraft operated by a holder of an air carrier operating certificate or an operating certificate; or 

(2) Any other aircraft while it is operated under IFR. 

(b) Paragraph (a) of this section does not apply to— 

(1) Portable voice recorders; 

(2) Hearing aids; 

(3) Heart pacemakers; 

(4) Electric shavers; or 

(5) 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. 

(c) In the case of an aircraft operated by a holder of an air carrier operating certificate or an operating 

certificate, the determination required by paragraph (b)(5) of this section shall be made by that operator of the 

                                                            

21 The ARC noted multiple examples where enforcement of an operator's PED policy resulted in conflict between 

crewmembers and passengers, or passengers with other passengers. The ARC discussed situations where 

noncompliance with crewmember safety instructions on the use of PEDs resulted in passengers being removed from 

an airplane, and in some cases, in-flight diversions. 

22 See AC 91-21.1B.
A Report from the PED ARC to the FAA

 Page 12 

aircraft on which the particular device is to be used. In the case of other aircraft, the determination may be made 

by the pilot in command or other operator of the aircraft. 

3.1 Regulatory History 

In 1966, the FAA first published regulations to address the use of PEDs. The first regulation, 14 

CFR § 91.19,23 was later superseded by §§ 91.21, 121.306, 125.204, and 135.144 to specifically 

address commercial operations. These regulations also placed the onus for determining what 

devices could be used on the individual operator. 

The rulemaking effort was prompted after the 1958-1961 studies of PED interference concluded 

that portable frequency modulation (FM) radio receivers caused interference to navigation 

systems such as VHF Omni Range (VOR) navigation systems. 

During that rulemaking process, the FAA received comments on the subject of FAA involvement 

in authorization of PED usage. The public expressed concern that authorization of devices not 

specifically excepted in the rule (i.e., portable voice recorders, hearing aids, heart pacemakers, 

electric shavers) would subject operators to a considerable amount of “red tape.” The FAA 

agreed and concluded that the airplane operator was best suited to make the determination of 

which PEDs would not cause interference with the navigation or communication system on the 

airplane. The FAA further recognized that requiring the FAA to conduct or verify tests of every 

conceivable PED, as an alternative to a determination made by the operator, would place an 

excessive and unnecessary burden on the Agency. 

3.2 Associated Regulations and Security Activity 

As the design of airplane and engine control systems evolved to use more advanced electrical 

and electronic control, the FAA determined that standardized regulatory policy and guidance was 

necessary to ensure these systems were sufficiently protected from environmental conditions that 

could have a negative impact. Airplanes that included fly-by-wire controls and electronic 

display systems were of particular concern because failures for these systems could be 

catastrophic. 

To address a known environmental threat, the FAA defined requirements for high-intensity 

radiated fields (HIRF) to provide assurance that newer airplanes with systems such as critical flyby-wire controls and electronic displays will have sufficient protection to continue to operate 

safely when exposed to HIRF. The FAA began assigning special conditions to airplane and 

system installation in 1987. In 2007, the FAA promulgated 14 CFR § 25.1317 and companion 

regulations for the other airplane categories.24 

These regulations resulted in protection of such systems from spurious emissions from PEDs and 

intentional transmissions from transmitting PEDs that could cause interference by direct 

coupling to the system’s wiring and apertures. However, HIRF protection does not provide 

avionics received systems (e.g., instrument landing system (ILS) and global positioning system 

(GPS)) from spurious emissions of PEDs and intentional transmissions from transmitting PEDs. 

                                                            

23 14 CFR 91.19, Docket No. 7247; Amdt 91-35 (later superseded by §§ 91.21, 121.306, 125.204, and 135.144). 

24 See also, 14 CFR Parts 23, 27, and 29. 
A Report from the PED ARC to the FAA

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3.3 Operational Allowance 

Today, the authority to allow the use of PEDs in flight rests with the operator under 14 CFR § 

91.21. Further, AC 91-21.1B provides guidance to the operator to make the determination that 

the operation of PEDs will not interfere with the safe operation of the airplane. Generally, 

operators have adopted guidance in AC 91-21.1B. 

Recommended Procedures for Operators 

Prohibiting the operation of any PEDs during the takeoff and landing phases of flight. It must be 

recognized that the potential for personal injury to passengers is a paramount consideration, as 

well as is the possibility of missing significant safety announcements during important phases of 

flight. This prohibition is in addition to lessening the possible interference that may arise during 

sterile cockpit operations (below 10,000 feet).25 

Operators have been hesitant to deviate from the recommendations outlined in AC 91-21.1B, as 

there has been no clear industry/regulatory guidance on methods to demonstrate an equivalent 

level of safety when expanding PED use into critical phases of flight. 

There is an additional burden on the airplane operator to insure that PEDs approved for use on 

board airplanes do not interfere with navigation and communication systems. 

Recommended Procedures for Operators 

Procedures for determining non-interference acceptability of those PEDs to be operated aboard its 

aircraft. Acceptable PEDs should be clearly spelled out in oral departure briefings and by written 

material provided to each passenger to avoid passenger confusion. The operator of the aircraft 

must make the determination of the effects of a particular PED on the navigation and 

communication systems of the aircraft on which it is to be operated. The operation of a PED is 

prohibited, unless the device is specifically listed in section 91.21(b)(1) through (4). However, 

even if the device is an exception from the general prohibition on the use of PEDs, an operator 

may prohibit use of that PED. The use of all other PEDs is prohibited by regulation, unless 

pursuant to section 91.21(b)(5). The operator is responsible for making the final determination 

that the operation of that device will not interfere with the communication or navigation system of 

the aircraft on which it is to be operated.26 

Each operator establishes a method by which this PED effects determination is made. A 

common method for making this determination is to compare each PED device against the 

current RTCA DO-160 standards for airborne equipment which has RF and Power emissions and 

transient allowances. As the consumer electronics industry has exploded in terms of device type 

and popularity, the requirement for each operator to fully evaluate each and every PED desired to 

be brought onboard an aircraft has become untenable. 

 3.4 FCC Regulations 

The FCC has established rules for radio transmitters and consumer electronic equipment to 

minimize the risk of harmful interference to other users of the airwaves. The FCC rules, with a 

few notable exceptions, do not prohibit use of radio transmitters or consumer electronic 

equipment aboard airplanes. 

                                                            

25 AC 91-21.1B at ¶6.F. 

26 AC 91-21.1B at ¶6.E. 
A Report from the PED ARC to the FAA

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The FCC standards for controlling interference from PEDs are essentially the same as those used 

elsewhere throughout the world. While these standards are not specifically designed to prevent 

interference from PEDs used on board airplanes, based on experience, there appears to be little 

risk of such interference from compliant devices. 

Since 1991, 47 CFR 22.925 has prohibited the airborne use of 800 MHz cellular phones. The 

ban was put in place because of potential interference to cellular networks on the ground. In 

early 2005, the FCC proposed rulemaking to lift this ban.27 In April 2007, the FCC terminated 

this proceeding, with the Commission noting that the “comments filed in this proceeding provide 

insufficient technical information that would allow the Commission to assess whether the 

airborne use of cellular phones may occur without causing harmful interference to terrestrial 

networks.”28 

Cell phones have recently been permitted by foreign carriers on international flights through use 

of pico-cells or miniature cellular base stations certified or approved for use aboard the aircraft. 

These pico-cells cease operation when the flight is over U.S. airspace, but there is growing 

interest in continuing operation when over the U.S. This raises the possibility that it may be 

appropriate for the FCC to again review its policies relative to cell phone use on planes, not only 

for international flights, but for U.S. domestic flights as well. Moreover, cell phone technology 

has advanced considerably since the last time the FCC reviewed the current rules, when usage 

was primarily focused on voice calls as opposed to the current widespread use of smart phones 

and devices for access to the Internet and various applications on board the airplane. These picocells cease operation when the flight is over U.S. airspace. 

The FCC has approved rules that allow in-flight voice and data services, including broadband 

services using dedicated air-to-ground frequencies that were previously used for seat-back 

telephone service. Air-to-ground service providers offer in-flight services, such as Internet 

access for laptop computers via Wi-Fi systems that have been certified for use on aircraft. 

Because these air-to-ground services operate on frequencies that are dedicated to air-to-ground 

communications and are separate from those used for wireless services on the ground, they do 

not pose an interference risk to wireless networks on the ground. 

Consumer devices using ultra-wideband technology are prohibited from operating on board 

airplanes due to the unique characteristics of this technology. This technology is not currently 

available in the form of PEDs. New Wi-Fi technology has been developed for the 60 GHz 

region of the spectrum. Such devices are currently prohibited from operating on board airplanes 

due to concerns about potential interference to radio astronomy. However, it is possible that this 

restriction may be revisited as 60 GHz devices may be introduced in the future for use in PEDs. 

 

                                                            

27 70 FR 11916 (March 10, 2005). 

28 72 FR 20439 (April 25, 2007). 
A Report from the PED ARC to the FAA

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4.0 NOTICE OF POLICY AND REQUEST FOR COMMENTS

This chapter addresses the ARC’s tasking to review the comments received from the Federal 

Register Notice. 

4.1 Federal Register Notice 

On August 31, 2012, the FAA published a Notice of Policy, Request for Comment regarding 

Passenger Use of Portable Electronic Devices on board Aircraft in the Federal Register.

29 The 

Agency sought comments on current policy, guidance, and procedures that aircraft operators use 

when determining if passenger use of PEDs may be allowed during any phase of flight on their 

aircraft. 

4.2 Assessment of Federal Register Comments 

The comment period closed on October 30, 2012, and resulted in 162 formal submissions, 854 

separate commenters, and a total of 1,062 discrete comments. The FAA Comment Compilation 

Team sorted the comments into different areas based on the questions posed in the Notice. The 

final compilation also tracked each comment by the type of submitter (noting industry 

stakeholder comments, passenger comments, as well as other types of submitters). 

The ARC members reviewed the compiled comments and discussed the results by each question 

category (or issue). From each category, the Chair gained consensus from the members as to 

when a potential key issue existed from which the ARC may desire to form/develop a 

recommendation. Thirty-two (32) specific key issues were identified and used to inform the 

ARC’s deliberations. 

The members used the 32 key issue areas to narrow the questions presented and formulate the 

ARC’s recommendations. A summary of the comments (by question category) appears below: 

(a) Technical requirements exist to make airplanes tolerant from any interference effects 

from PEDs: Members noted that the work done by RTCA SC-202 laid an excellent 

foundation for establishing PED tolerant airplanes and a focused review. The 

Technical Subcommittee reviewed RTCA guidance documents DO-307, DO-294, and 

DO-160, as well as FAA AC 91-21.1B and AC 20-164 among other documents to 

determine ways to make airplanes PED tolerant using some mix of voluntary or 

mandatory methods. The ARC delineated three distinct categories of airplanes to 

consider: Airplanes that are 1) part of today's fleet; 2) being manufactured today or in 

the medium-term future under existing type certificates; and 3) being newly designed 

to be built under new type certificates. 

                                                            

29 77 FR 53159 (Docket No. FAA-2012-0752). 
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(b) Comments from individuals identified as passengers (not associated with any 

particular industry group) indicate a growing belief that PED usage causes no harm to 

today's airplanes: Many respondents commented that they intentionally do not follow 

operator instructions when told to power off their PEDs. The respondents are 

convinced that there is absolutely no harm that can be caused by PEDs and that 

concerns are outdated and should have been dealt with long ago by the FAA. These 

and other passenger views prompted the ARC to focus one aspect of its work on 

safety communications recommendations that, regardless of the outcome of the 

expanded usage determination, will be integral to assuring passenger acceptance of 

and compliance with future operator and FAA PED usage policies. 

(c) Standards and consistency around PED stowage requirements: Passengers support 

stowing PEDs when they are assured it is necessary for safety from a projectile or 

egress perspective. Additionally, it is also clear that passengers desire to have a 

consistent flying experience as they travel. 

• Domestically 

• Internationally 

• From Airline to Airline 

• From Airplane to Airplane within an Airline 

Further, there is a lack of guidance regarding passenger personal items that must be 

stowed for takeoff and landing (i.e., a hard cover book can be held by a passenger, 

while a purse must be stowed). The Safety Communications subcommittee 

considered this issue in detail in its recommendations. 

(d) Standards within the consumer electronics industry for airplane-friendly PEDs: Most 

commenters like this idea but committee discussions on this have surfaced how 

difficult this would be to implement. The members of the ARC who represent the 

PED manufacturing community indicate an openness to consider some type of 

expanded device testing and tagging to allow acceptable operator use; however, they 

note that their industry now increasingly displays such information electronically 

rather than with a physical device tag. Even if physical device tags were developed, 

they would have to be of sufficient size and brightness to be clearly visible to a 

crewmember in the aisle when held in a window seat, with some tamper- and 

counterfeit-resistant features. Also, today's PEDs typically combine multiple 

transmission modes (e.g., Bluetooth, cellular, Wi-Fi) with new modes envisioned for 

the near future, adding to the complexity of device tagging. Further, the committee 

observes that many passengers may be unaware of the communication mode used by 

their devices, and may therefore find it difficult to confirm that their device is in a 

"safe" operating condition; this would lead to unacceptable confusion and possible 

interpersonal friction during inflight operations. 
A Report from the PED ARC to the FAA

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(e) Consistency in use with flight and cabin crew PEDs such as a cockpit Electronic 

Flight Bag (EFB) device(s): Airlines are proceeding to adapt PEDs for EFB and 

Cabin product use; restrictions on the use of such devices may differ from those 

applied to passenger devices today, or to future operator policies that allow for 

expanded PED use by passengers. The ARC recognizes that a mixed safety message 

potentially exists if an operator crew member is using a PED during a time when the 

operator has said a passenger device is not safe to operate. The ARC further notes that 

crewmember PEDs have been specifically authorized by the FAA for use in flight by 

crewmembers. The operational authorization is achieved by meeting specific FAA 

requirements that include restrictions on the type of software allowed to be used in 

flight. 

(f) Operational challenges of interference with passenger medical devices and impact on 

autistic passengers were identified: Medical devices on board an airplane may 

require continuous operation; however, the ARC has been unable to confirm that 

medical devices are tested against DO-160 equivalent emissions standards to verify 

compatibility for airborne operation. Autism was mentioned by a number of 

respondents who indicate autistic patients, especially children, may have negative 

behavioral reactions during takeoff and landing when their attention is not engaged by 

PEDs. The ARC notes that many operators already have a process in place to 

evaluate specific medical devices for special needs passengers, which involves 

evaluating each device on an individual basis. 

(g) SMS and other risk-based assessments were incorporated in ARC Recommendations: 

Many of the commenters requested that PED policies ensure airplane operational 

safety. This is a universal objective of all of the PED ARC committee members; 

however, balancing safety, economic impact, and passenger convenience is the 

challenge. To address this need, the PED ARC recommends adapting the SMS 

approach to develop a comprehensive risk-based assessment tool. Service Difficulty 

Report (SDR) data, Operator Interference data, and Manufacturer/Supplemental Type 

Certificate Installer test data are recommended inputs into the SMS model analysis. 

(See Section 6.1 of this report.) Further, operators have guidance on determining the 

severity of hazard from the ARC’s work summarized in Appendix F, Avionics 

System Functional Hazard Risk Assessment. 

5.0 CONSTITUENCY DESCRIPTIONS

This chapter describes the various constituencies that comprise the ARC membership. Each 

member or participant on the ARC was selected to represent an identified stakeholder group or 

industry segment, and because the member possessed the expertise and qualifications to speak 

for that constituency. The FAA wanted to achieve a balance between the regulator, regulated 

parties, other industry stakeholders, and the flying public. 

As a result of the varied constituencies, the ARC was able to engage in meaningful debate on a 

sound, risk-based methodology for expanding the use of PEDs, and all of the constituencies 

contributed to the discussions on the technical, operational, and safety communications key 

issues. The ARC also invited additional participation by FAA and other federal and international 
A Report from the PED ARC to the FAA

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regulatory authority SMEs to support the members as they collected information and data and 

debated recommendations. 

The membership encompassed seven constituent groups representing stakeholders involved in all 

aspects of the PED use debate. 

5.1 PED Manufacturers and Distributors 

The FAA invited Amazon.com and OnAsset Intelligence, Inc., as well as the Consumer 

Electronics Association (CEA) which represents 2,000 companies across the consumer 

electronics industry, to participate in the ARC. These PED industry representatives brought an 

important perspective to the ARC deliberations. They described their customers’ experiences, 

observations, and questions about PED use aboard aircraft. They also discussed FCC-mandated 

testing and other testing required for PEDs, as well as industry practices regarding regulatory 

compliance. In addition, CEA was able to share consumer research survey findings specifically 

related to the in-flight use of PEDs, as well as a similar survey conducted ten years earlier.

5.2 Pilot and Flight Attendant Groups 

The membership included representation from the Air Line Pilots Association, International 

(ALPA), the largest airline pilot union in the world, and the Association of Flight AttendantsCWA (AFA-CWA), the world's largest flight attendant union. These members were invited to 

participate to address crewmembers' safety concerns as they relate to expanded use of PEDs. 

5.3 Aircraft Operators 

The membership encompassed four 14 CFR Part 119 certificated air carriers and two industry 

associations. Delta Airlines, JetBlue Airways, American Airlines, Executive Jet Management, 

the Regional Airline Association (RAA) which represents North American regional airlines, and 

the Helicopter Association International comprised the operator contingent. These air carrier and 

industry association members were able to educate the other members on the current approval 

process(es) associated with PED usage policies, as well the practical challenges associated with 

demonstrating PED-tolerance to the FAA in order to obtain approval for the expanded use of 

PEDs. 

5.4 Passenger Experience Associations 

The membership included two passenger experience associations. The Airline Passenger 

Experience Association (APEX) is a network of the world’s leading airlines, suppliers and 

related companies committed to elevating the level of the passenger experience. The National 

Association of Airline Passengers is a nonpartisan, nonprofit organization dedicated to 

preserving and protecting passenger rights and representing the passenger constituency. 

5.5 Airplane and Avionics Manufacturers 

The membership included three airplane manufacturers―The Boeing Company, Airbus, and 

Cessna Corporation, as well as two industry trade associations representing airplane 

manufacturers. The General Aviation Manufacturers Association (GAMA) represents 80 of the 
A Report from the PED ARC to the FAA

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world’s leading manufacturers of general aviation airplanes and rotorcraft, engines, avionics, 

components and related services, and the Aerospace Industries Association (AIA) represents the 

nation’s leading manufacturers and suppliers of civil, military, and business airplane, helicopters, 

unmanned airplane systems, space systems, airplane engines, missiles, materiel and related 

components, equipment, services and information technology. The ARC membership also 

included three avionics manufacturers―Garmin, Thales, and Rockwell Collins. The 

airplane/avionics manufacturer constituency spent a substantial amount of time educating the 

members on PED-tolerant airplanes and the testing required for an operator to obtain operational 

authorization for PED usage. 

5.6 Federal Aviation Administration 

FAA representation on the ARC included members from the Aircraft Maintenance Division 

(AFS-300), Office of the Chief Counsel (AGC), and the AVS Chief Scientific and Technical 

Advisor for Aircraft Electromagnetic Compatibility. In addition, several FAA subject matter 

experts participated in the ARC, including representatives from the Aircraft Engineering 

Division (AIR-100), Air Transportation Division (AFS-200), Office of Communications (AOC) 

and Office of Rulemaking (ARM). FAA members and participants supported the efforts of the 

ARC by facilitating discussion of the current regulatory framework for usage of PEDs; 

conducting briefings on a number of technical and regulatory issues; reviewing and cataloging 

comments submitted in response to the Federal Register Notice; and answering questions for the 

members. 

5.7 Other U.S. and International Regulatory Authorities 

In addition to the members and SMEs from the FAA, ARC members included representatives 

from the FCC and TSA. To the extent the work of the PED ARC overlapped areas within the 

authority of the FCC, the FCC member was available to clarify current FCC rules and discuss 

changes in the rules that the Commission has either proposed or may consider in the future. The 

FCC representative also briefed the members on developments in the use of the radio spectrum 

and radio frequency devices, including the advances in medical devices that are now and will in 

the future be carried by many passengers. The TSA representative was available to address the 

overlap between operational/technical considerations and the associated security concerns. At 

the outset of the ARC, members expressed a desire to harmonize its efforts with the international 

aviation community and requested that the FAA reach out to counterpart international safety 

organizations in Europe. A representative from the European Aviation Safety Agency (EASA) 

served on the ARC, and representatives from the United Kingdom Civil Aviation Authority 

(U.K. CAA) and Transport Canada (TC) participated on the ARC to discuss companion 

international efforts to harmonize PED usage policies. 
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6.0 THRESHOLD RECOMMENDATIONS

The ARC developed threshold recommendations to address the core concepts consistent across 

all aspects involved in expanding PED usage. These recommendations apply to the technical, 

operational, and safety communications recommendations that appear in later chapters of this 

report. 

6.1 SMS Methodology 

To support expanded PED usage on airplanes, the ARC studied the FAA SMS methodology as 

one method for risk mitigation.30 The key elements of the SMS process involve identifying 

hazards associated with the introduction of any new system and determine the likelihood and 

most probable outcome of the existence of the hazard. The SMS approach forces a risk 

determination for each hazard and if the risk is found unacceptable, forces a review of actions 

that could be taken to mitigate the risk to an acceptable level. 

The ARC endeavored to find as many data sources as possible to determine the number of 

confirmed occurrences of PED interference with aircraft systems. Several members studied data 

sources and compiled information that was presented to the ARC, including analysis of Service 

Difficulty Reports (SDR), ASRS Reports, operator reports, and information from multiple 

Supplemental Type Certificate (STC) holders (conducting new system certification testing). To 

the extent such information is not proprietary and/or could be de-identified, it is included in 

Appendix I of this report. 

The ARC noted the difficulty that each of these sources had in confirming PEDs as a source of 

interference. However, each data set appeared to contain sufficient information to determine if 

an event was or was not related to PED interference. As there is difficulty in confirming PED 

interference across these data sources, the ARC recommends that an SMS risk assessment be 

conducted so that it captures some or all suspected PED interference events to obtain a 

conservative frequency of occurrence. 

PED designs have also improved over time. Devices today emit much less power as 

manufacturers have sought to extend battery life.31 Transmitting PED designs have also been 

improved to insure devices stay within a tighter range of frequencies and transient noise 

envelopes. These factors have contributed to a PED population with much less potential to cause 

system interference. See Figure 1 below. 

                                                            

30 See generally, Federal Aviation Administration Office of Aviation Safety SMS Guidance at 

http://www.faa.gov/about/initiatives/sms/. 31 See Radio-Electronics.com (http://www.radio-electronics.com/info/cellulartelecomms/gsm_technical/powercontrol-classes-amplifier.php). 
A Report from the PED ARC to the FAA

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Figure 1 – Average Life of PC/Tablets in Use (Years)32

For example, where devices such as portable FM radios, TV receivers, CD players and electronic 

hand-held games were popular years ago, today passengers are more likely to be carrying ereaders, tablet and laptop computers, music players, and smart phones that can operate in 

airplane mode. Many of these products have life-cycles of only a few years due to the rapid 

introduction of newer and better products. Accordingly, the specific device types that may have 

caused issues in the past may no longer be relevant today.33 

Recommendation #1—The ARC recommends that the FAA conduct an SMS risk 

assessment and engage safety experts on its staff and across industry to look for hazards 

associated with PED interference potential. While the PED ARC membership included 

some system expertise to identify hazards, it is suggested that a more focused group 

could develop a complete list of hazards that should be risk-assessed to SMS standards. 

To support the expanded use recommendations proposed by the ARC, the members 

further recommend a safety risk assessment, as outlined in Appendix F of this report. 

As the SMS process is relatively new to the aviation community, the ARC also encourages the 

FAA to assign SMEs from the SMS Program Office to aid in the SMS risk assessment. 

                                                            

32 Daniel Research Group (2013) June 2013: United States PC, Tablet, & Mobile Phone Market Size and Forecast. 

Daniel Research Group. 

33 For example, portable FM radios included local oscillators that tended to generate significant spurious emissions 

on aeronautical frequencies, but such devices are no longer prevalent in the market. 
A Report from the PED ARC to the FAA

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6.2 Harmonization 

Passengers worldwide must be comfortable and have sufficient knowledge to understand that 

airplanes are tolerant against PED emissions. Passengers are also looking for standardized, 

reasonable operator PED stowage requirements that balance societal expectations against 

projectile and egress risks. If a worldwide effective communication strategy is achieved, then 

the ARC believes the FAA will be positioned as a leader in international efforts to promote 

harmonization in this area. 

Recommendation #2—The ARC recommends that the FAA promote harmonized policy 

with international regulatory authorities, including EASA, such that the recommendations 

made in the ARC report are universally accepted by international regulatory authorities. 

The ARC encourages the FAA to use the International Air Transport Association (IATA) 

and the International Civil Aviation Organization (ICAO) as forums to promote expanded 

PED usage policy within the recommended safety framework. 

The ARC notes that its recommendations in the technical, operational, and safety 

communications areas discussed below are all important to the universal acceptance of expanded 

allowance policies for PED usage in flight. 

6.3 Standardization 

The ARC encourages the FAA to set the standard for PED usage and stowage and encourage 

operators to only differ from a standard when absolutely necessary to mitigate an unacceptable 

risk condition. With regard to all article stowage standards, the ARC found that there has been 

very little policy, guidance, and analysis done with respect to what type of objects should be 

allowed to be out and in use during takeoff and landing. The FAA should use this opportunity to 

not only define what types of PEDs could be out and in use during takeoff and landing but define 

all article standards as well. 

Recommendation #3—The ARC recommends that the FAA standardize the travelling 

experience for consumers such that they come to expect a consistent approach from air 

carriers regarding PED usage and stowage requirements. 

The ARC received comments through the docket and our various constituencies that passengers 

do not like or understand why PED usage and stowage are different from air carrier to air carrier. 

Neither a lack of understanding of differences by passengers, nor an explanation by air carriers 

that it is “airline/operator policy” or “FAA required,” is an acceptable practice going forward. 

Society has changed to where PEDs are an integral part of our everyday lives. The public 

expects and this ARC recommends that the FAA clearly articulate what is an acceptable risk 

with respect to device type and ensure confidence in the public that a proper risk assessment has 

been done. 
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7.0 TECHNICAL RECOMMENDATIONS

In addressing the technical questions associated with expanding passenger use of PEDs to all 

phases of flight, the ARC reviewed many data sources, and received many technical briefings, 

involving the RF characteristics of typical PEDs and of PED-tolerant airplanes, as well as the 

manner by which operators may demonstrate compliance with applicable standards. The 

technical recommendations were formulated to address airplane certification requirements as 

well as methods to enable airplane operators to allow expanded passenger PED use to all phases 

of flight. 

7.1 Airplane Certification Requirements for New Airplanes 

The ARC determined that, in order to ensure that airplanes are PED-tolerant, it would be 

appropriate to start with recommendations to address airplanes not yet produced (those for which 

a type certificate is required under 14 CFR Part 23 [commuter category only] or Part 25). In 

developing the recommendations associated with airplane certification, the ARC’s intent was to 

apply the standards to new airplanes. 

Recommendation #4―New Type Certificate Applications: The ARC recommends 

that the FAA require PED tolerant (i.e., RTCA DO-307 certified) airplane designs for all 

new type certificates issued for airplanes under 14 CFR Part 23 (commuter category 

only) or Part 25. 

Recommendation #5―New Derivative Certificate Applications: The ARC 

recommends that the FAA require PED tolerant (i.e., RTCA DO-307 certified) airplane 

designs for all new derivative certificates issued for airplanes under 14 CFR Part 23 

(commuter category only) or Part 25. 

Recommendation #6—New Avionics, Major Changes in Type Designs: The ARC 

recommends that the FAA require new avionics system(s) installations that are 

considered major changes in type design (Supplemental Type Certificate [STC] or 

Amended Type Certificate [ATC]) with catastrophic failure classifications demonstrate 

PED tolerance (i.e., RTCA DO-307 certification) for those systems when certificated on 

airplanes under 14 CFR Part 23 (commuter category only) or Part 25. For new avionics 

system(s) installations that are considered major changes in type design (STC or ATC), 

where the systems are required by operating part or with major or hazardous failure 

classifications, and cannot demonstrate PED tolerance, a safety risk assessment (as 

discussed in Section 7.3 below) must be accomplished for those systems. 

Recommendation #7―The ARC recommends that associated FAA guidance 

documents, including AC 20-164 and AC 91-21.1B, be evaluated to incorporate 

alternative approach(es) to allow certification of individual systems for PED tolerance. 

Suggested revisions may also include changes to RTCA DO-294 guidance applicable to 

14 CFR Part 119 certificate holders and considerations for the operating environment.

The ARC also believes that the FAA should periodically review RTCA DO-307 (Sections 3 and 

4) and the document’s capacity to provide guidance for the conditions above and work with the 

RTCA to amend DO-307 as appropriate. 
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7.2 Airplane Certification Requirements for Airplanes Currently in Production 

In discussing how the FAA can establish requirements to allow operators to implement 

expanding passenger use of PEDs, the ARC acknowledged the concerns raised by operators 

about the cost of modifications and the importance of expanding PED usage to existing inservice airplanes. The ARC decided that a phased approach should be available for existing 

(legacy) airplanes. When reviewing how this policy could be implemented on airplanes currently 

being produced, the ARC determined that the recommendations provided in Section 7.3, below, 

will cover production airplanes or the operators of those airplanes that have obtained 

documentation indicating that those airplanes are PED tolerant. 

Recommendation #8―Newly Manufactured Airplanes: The ARC recommends that 

the FAA implement operational regulations that require all newly manufactured 

airplanes, which will be operated by 14 CFR Part 119 certificate holders under 14 CFR 

Parts 121 or 125, to be shown to be PED tolerant (i.e., RTCA DO-307 certified). This 

requirement would also apply to avionics system(s) installations that are considered 

major changes in type design (STC or Amended Type Certificate [ATC]) with 

catastrophic failure classifications, or equipment required by operating part, incorporate 

PED tolerant (i.e., RTCA DO-307 certification) designs when certificated on airplanes 

under 14 CFR Part 23 (commuter category only) or Part 25. 

For avionics system(s) installations that are considered major changes in type design 

(STC or ATC), where the systems are required by operating part or with major or 

hazardous failure classifications, and cannot demonstrate PED tolerance, a safety risk 

assessment (as discussed in Recommendation #10) must be accomplished for those 

systems. 

These regulations should have a compliance date no later than December 31, 2015. The 

FAA should grant petitions for limited extensions for operators introducing aircraft with 

extenuating circumstances, when justified. 

7.3 Enabling Airplane Operators to Permit Expanded Passenger PED Use 

The ARC reviewed AC 91-21.1B and other available information and found that the FAA has 

sufficient information to revise AC 91-21.1B to allow airplane operators (under 14 CFR Parts 

91K, 121, and 135) to permit expanded passenger PED use to additional phases of flight, noting 

that the incorporation of recommended safety risk management processes would enable 

operators to analyze whether to allow the expanded use of PEDs for the airplanes that they 

operate. 

Recommendation #9―The ARC recommends that the FAA modify AC 91-21.1B (and 

any associated guidance) to provide processes by which operators can demonstrate 

compliance with 14 CFR Section 121.306, 125.204, or 135.144, as applicable, in order to 

allow expanded use of PEDs to all phases of flight. Consideration should be given to 

maintaining cabin safety requirements (e.g. attention to safety announcements) when 

expanding PED usage. 
A Report from the PED ARC to the FAA

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Recommendation #10—The ARC recommends that in revising AC 91-21.1B (and any 

associated guidance), the FAA adopt the following methodology for expanding PED 

usage by passengers to all phases of flight. In particular, the FAA should immediately 

amend/revise current regulatory guidance documents to provide a methodology by which 

operators can permit PED usage by passengers during all phases of flight, using one of 

the following two methods:34 

Method 1. The operator may perform PED tolerance testing, or the operator may 

document evidence of testing by an airplane manufacturer or other entity, that 

demonstrates airplanes are PED- tolerant in accordance with Sections 3 and 4 of RTCA 

DO-307. 

Method 2. The operator may validate that its airplane and operations meet the 

requirements and limitations of the safety risk assessment proposed by the ARC for 

adoption by the FAA (attached as Appendix F to this report) for the phases of flight 

(identified as Phases 1-8 in Figure 2 below) in which the operator wants to allow 

expanded passenger PED use. The ARC’s proposed FAA safety risk assessment 

addresses both back door and front door effects. Mitigations are supported by flight 

experience, analysis, and test data, and are provided for all failure condition 

classifications of Major and above, as well as for equipment required by operational rule. 

Back door effects are assumed to be covered by an airplane’s HIRF certification of 

critical systems. If an airplane is not HIRF-certified, or has not had other back door 

interference testing completed, additional analysis and systems testing may be required. 

 

                                                            

34 Although Advisory in nature, AC 91-21.1B contains the statement that the operators PED usage program “should 

provide the following: ... f. Prohibiting the operation of any PEDs during the takeoff and landing phases of flight. It 

must be recognized that the potential for personal injury to passengers is a paramount consideration, as well as is the 

possibility of missing significant safety announcements during important phases of flight. This prohibition is in 

addition to lessening the possible interference that may arise during sterile cockpit operations (below 10,000 

feet).” Operators will need updated guidance from the work done in this ARC and RTCA SC-202 in place of this 

language. 
A Report from the PED ARC to the FAA

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Figure 2 – Phase of Flight 

Pursuant to this method, operators may permit passenger use of typical PEDs as follows: 

a) During any of the following phases: 

1 Parked: Passenger boarding and seating to door close. 

2 Taxi Out: Push back, taxi from gate to (but not including on) the runway. 

4 Climb: From ‘transition to climb altitude’ and/or gear retraction to en route altitude. 

5 Cruise: From en route altitude to beginning of descent with intent to land. 

6 Descent: From beginning of descent to the initiation of the approach. 

8 Landing and Taxi to Gate: Begins at airplane touchdown, and concludes when airplane is 

 parked for passenger unloading. 

b) 3 Take-off and Departure: During this phase if a qualitative safety risk assessment is 

 accomplished, and controls and mitigations are in place. 

c) 7 Approach: During this phase in visual approaches. 

d) 7 Approach: During this phase on instrument landings in visual meteorological conditions if a 

 qualitative safety risk assessment is accomplished, and controls and mitigations are in place. 

e) 7 Approach: During this phase on instrument landings in CAT I conditions if qualitative safety 

 risk assessment is accomplished, and controls and mitigations are in place. 

f) 7 Approach: During this phase on instrument landings in CAT II or CAT III conditions if 

 testing and analysis shows that systems with Major, Hazardous, or Catastrophic failure 

 conditions are determined PED tolerant. 

The ARC recognizes and supports consistent application of expanded PED use policies across 

the aviation industry to reduce passenger confusion and inconsistency between different operator 

PED usage policies. Operators are encouraged to adopt standard usage profiles across flight 

phases to minimize passenger confusion. Operator decisions on expanded usage should take into 

account the goal of achieving stronger adherence to the usage policies. 

1 2 3 4 5 6 7 8

Parked Taxi Takeoff &

Departure

takeoff to

transition‐to‐

climb altitude

and/or gear

up

Climb Cruise Descent

to IAF

and/or flaps

Approach

IAF or flaps

to visual

reference to

landing

Landing

&  

Taxi to

Gate

10’000 AGL 10’000 AGL
A Report from the PED ARC to the FAA

 Page 27 

Recommendation #10 Method 2: Dissent Position 

Commercial air transportation is one of the safest modes of travel available. But it is in thinking 

about what could go wrong that makes it so. The PED ARC group that disagrees with the 

majority’s Recommendation #10 above (aka, the Dissenting Group) include five individuals 

employed by the four organizations on the ARC that represent airline pilot; cabin crew; 

passenger; and entertainment, communications, IT and connectivity equipment issues: the Air 

Line Pilots Association, International; Association of Flight Attendants-CWA; National 

Association of Airline Passengers, and Airline Passenger Experience Association; respectively. 

The Dissenting Group supports expanded use of Portable Electronic Devices (PEDs), as long as 

such use is shown to be safe. However, it is the opinion of the Dissenting Group that a key 

recommendation contained within the majority’s Recommendation #10, above, does not 

adequately satisfy this requirement. 

According to Section 1.0 of this report, “In the Notice, the FAA indicated the desired outcome of 

the Request for Comments was to have sufficient information to allow operators to better assess 

whether more widespread use of PEDs during flight is appropriate, while maintaining the highest 

levels of safety to passengers and aircraft.” It is important to note the desired outcome was not a 

guarantee that gate-to-gate use of PEDs would be the result, but only expanded use of PEDs 

while maintaining the highest levels of safety. Section 1.0 also states that the “PED ARC made 

recommendations to further clarify and provide guidance on allowing additional PEDs without 

compromising the continued safe operation of the aircraft.” 

Neither full nor general consensus35 for all of the PED ARC recommendations was achieved; 

therefore, this section documents the dissenting position and provides an alternative to a key 

PED ARC recommendation to airline operators concerning so-called “legacy” aircraft; i.e., any 

aircraft not designed and manufactured, or otherwise determined to be, PED tolerant. 

The regulatory history discussion in Section 3.1, above, notes that early studies of PED 

interference concluded that portable frequency modulation (FM) radio receivers caused 

interference to navigation systems such as VHF Omni-directional Range (VOR) navigation 

systems. While use of FM radio receivers seems unlikely today the VOR navigation system is 

                                                            

35 FAA, AVS Quality Management System: ARM Committee Process, ARM-001-015, March 5, 2013. From Sec. 4.1 

DEFINITIONS RELATED TO CONSENSUS: Full consensus means all members agree fully in context and 

principle and fully support the specific course of action; General consensus means that, although there may be 

disagreement, the group has heard, recognized, acknowledged, and reconciled the concerns or objections to the 

general acceptance of the group. Although not every member fully agrees in context and principle, all members 

support the overall position of the ARC and agree not to object to the proposed recommendation report; Dissent

means a differing in opinions about the specific course of action. There may be times when one, some, or all 

members do not agree with the recommendation or cannot reach agreement on a recommendation. From 4.2.2.3 

Dissenting Position: “If a member or members do not concur with one of the recommendations or the entire 

recommendation report, then this dissenting position is documented in the recommendation report.” 
A Report from the PED ARC to the FAA

 Page 28 

still in use on most transport category aircraft. While many may feel that newer navigation 

systems such as GPS will make the VHF Omni-directional Range system obsolete, it may be of 

interest to realize that Ground Based Augmentation Systems (GBAS) that increase the accuracy 

of GPS for landing approach guidance will transmit correction signals to the GPS position via 

VHF radio transmissions. 

While RTCA Special Committee SC-177 indicated that the probability of interference to 

installed aircraft systems from PEDs, singly or in multiples, is low at this time the Special 

Committee, nevertheless, stated, “However, the possibility of interference to aircraft navigation 

and information systems during critical phases of flight, e.g., takeoff and landing, should be 

viewed as potentially hazardous and an unacceptable risk for aircraft involved in passengercarrying operations.”36 This is the basis for the guidance material contained in Advisory Circular 

AC 91.21-1B, which states: “It must be recognized that the potential for personal injury to 

passengers is a paramount consideration, as well as the possibility of missing significant safety 

announcements during important phases of flight. This prohibition is in addition to lessening the 

possible interference that may arise during sterile cockpit operations (below 10,000 feet).”37 

This brings us to the recommendation regarding expanded PED use within the existing fleet of 

aircraft (as well as any near term future acquisitions of aircraft not yet determined to be PED 

tolerant) that is contained in Section 7.3, above; the Dissenting Group cannot agree with Method 

2 of the majority’s Recommendation #10 as it is written. Currently, Method 2 of the majority’s 

Recommendation #10 allows an operator to use the Safety Risk Assessment (SRA) for the 

phases of flight in which the operator wants to allow expanded passenger PED use. As part of 

this SRA, mitigations have to be developed to address situations in which the risk is determined 

to be unacceptable. One of these mitigations would be to remove the threat by having passengers 

turn off their PEDs. But because this method allows the SRA to be conducted by phase of flight, 

such mitigation (passengers turning off PEDs) could be applied only for specific phases of flight 

in which the SRA has determined system severity to be Major, Hazardous, or Catastrophic. An 

example used in discussions was ILS CAT II approaches. 

In this example, assuming the risk to the ILS CAT II approach system was determined to be 

Major or above, a suggested mitigation would be to have passengers turn off their PEDs when 

the weather was low enough to require the use of the ILS CAT II approach system. It was 

suggested that improved passenger compliance would result since passengers can “see” that the 

weather is poor. First, low visibility approaches that require use of the ILS CAT II system may 

be due to fog which may not be encountered until shortly before landing. In this case the 

passengers may only see sunshine and blue skies until just before landing. Second, making an 

announcement to turn off PEDs may unnecessarily scare some passengers. Third, this “phase of 

flight” approach will not afford the common passenger experience desired by the PED ARC. 

                                                            

36 RTCA DO-233, page 1 Executive Summary 

37 AC 91.21-1B, paragraph 6.F. 
A Report from the PED ARC to the FAA

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Fourth, the safety of the aircraft should not be dependent on passenger compliance to turn off 

their PEDs; the passengers are not responsible for the safe operation of the aircraft. 

Additionally, this recommendation allows an operator the opportunity to avoid doing anything, 

for any phase of flight, to achieve expanded PED use in its legacy fleet. The Dissenting Group 

supports expanded PED use for passengers as long as such expansion is shown to be safe and not 

merely “deemed” as such. 

The argument has been made that requesting passengers turn off PEDs in the future will be no 

different than what is done today. However, the Dissenting Group believes that it is different 

since the current 10,000 ft. policy is being applied uniformly today. Under the PED ARC 

majority’s recommendation, compliance will be difficult to ensure consistently because it could 

be different from flight to flight. 

The Dissenting Group is also of the opinion that any proposed change in policy regarding 

expanded use of PEDs should be transparent to the flight crew; i.e., that there should be no 

additional crew workload created by having to turn off landing navigational aids or make 

announcements to turn off PEDs during certain phases of flight and weather conditions. The 

flight crew’s job should be simply to fly the aircraft and manage safely its energy and trajectory. 

Ultimately, after allowing a reasonable period of time to accomplish a system-wide transition to 

“PED tolerant” aircraft, the Dissenting Group believes that if an airline operator needs to rely on 

passenger compliance with a crewmember’s instructions as a way to mitigate potentially major, 

hazardous or catastrophic conditions on a particular airplane, that airplane should be modified or 

otherwise be determined to be PED tolerant. 

If operators choose, for any of their airplane configurations that are not already determined to be 

DO-307 compliant, to not perform PED tolerance testing or obtain evidence from an aircraft 

manufacturer or other entity demonstrating PED tolerance in accordance with Sections 3 and 4 of 

RTCA DO-307, the Dissenting Group recommends that these operators perform instead 

comprehensive Safety Risk Assessments, based on guidance from the FAA Safety Risk 

Management Panel, to identify hazards associated with expanded PED use to all 

communications, navigation, and surveillance equipment on those aircraft configurations. To 

expand the use of PEDs on these aircraft, an operator can use the SRA results to identify systems 

that are susceptible to PED EMI and ensure those systems comply with applicable sections of 

DO-307. 

The PED ARC was tasked with looking into safely expanding the use of PEDs, which implies 

that the “status quo” is acceptable. To say it isn’t implies that today’s operations are unsafe. The 

Dissenting Group has concerns that the majority’s Recommendation #10, above, allows an 

operator to expand use of PEDs by “opting out” during certain flight phases. The Dissenting 

Group is of the opinion that if an operator wishes to expand the use of PEDs below 10,000 feet 

AGL then this means ALL operations below 10,000 feet AGL under all weather conditions 

(notwithstanding stowing items of mass for takeoff and landing). 
A Report from the PED ARC to the FAA

 Page 30 

The Dissenting Group alternative language for Recommendation #10 follows below. This 

alternative recommendation will enable 14 CFR Parts 91, 119, 121, and 135 aircraft operators 

the ability to allow expanded PED use on aircraft not otherwise fully PED tolerant. The ARC 

members reviewed AC 91.21-1B and other available information and found that the FAA has 

sufficient information to revise AC 91.21-1B, noting that the incorporation of DO-307 testing 

and/or recommended safety risk management processes will enable operators to allow the 

expanded use of PEDs for the aircraft that they operate. 

Recommendation #10 Dissent Position—The ARC recommends that the FAA 

modify AC 91.21-1B (and any associated guidance) to provide methods by which 

operators can demonstrate compliance with PEDs during all phases of flight. By 

January 1, 2017 all operators will allow expanded use of PEDs during all phases 

of flight on all of their airplanes, consistent with the limits imposed by cabin item 

stowage policies as allowed by the FAA, through either of the following two 

methods: 

Method 1: The operator may perform PED tolerance testing or properly document 

evidence from an aircraft manufacturer or other entity that demonstrates the 

airplane is PED-tolerant in accordance with Sections 3 and 4 of current version of 

RTCA DO-307. 

Method 2: The operator may perform a Safety Risk Assessment (SRA) on each 

airplane model configuration in their inventory, following the process developed 

by the FAA Safety Risk Management Panel (SRMP) and attached in Appendix F. 

If the operator’s SRA indicates a hazard class of CATASTROPHIC exists for a 

particular system, the risk must be controlled by compliance with the applicable 

sections of DO-307 (front door and back door, as applicable). If the SRA 

indicates a hazard class of MAJOR or HAZARDOUS for a failure mode of 

“misleading information” for a particular system, the risk must be controlled by 

the following process: a) Test the system to determine if it meets the standards in 

the applicable sections of DO-307 (front door and back door, as applicable), or an 

acceptable alternative; if not, b) Modify the system such that it meets the 

standards in the applicable sections of DO-307 (front door and back door, as 

applicable), or an acceptable alternative. 

Before completing either Method 1 or Method 2 above for a particular airplane 

model configuration, an operator must continue to operate that specific 

configuration under existing PED usage policies, which include the turning off 

and stowing of PEDs below 10,000 feet Above Ground Level (AGL). In 

discussing how the FAA can implement changes to require that PED tolerance be 

demonstrated for all aircraft, the ARC acknowledges concerns raised by aircraft 

operators regarding the cost and operational impacts of aircraft testing and 

modifications, as well as the ability to transition their operations to system-wide, 
A Report from the PED ARC to the FAA

 Page 31 

expanded PED usage policies. To address these concerns, if an operator finds it 

difficult or cost-prohibitive to achieve full, expanded use of PEDs using either 

method above for one or more specific combinations of airplane model 

configuration and operation, the operator must prohibit PED usage below 10,000 

feet AGL, or when the aircraft is “in-range” if cruising below 10,000 feet AGL.38

This restriction only applies to those specific airplane model 

configurations/operations that the operator demonstrates to the FAA that 

implementation of a full-expanded PED usage policy is resource-prohibitive. Use 

of this restricted policy option is available only until January 1, 2017; beyond this 

date, all operators will ensure that all of their aircraft are determined to be PEDtolerant using either Method 1 or 2, above. 

Since we have a dissenting opinion on Recommendation #10, our dissent also applies to 

Recommendation #19: We do not concur that all of the “approaches set up in the ARC for 

expansion of use as acceptable methods for compliance with PED use regulations” should be 

provided to operators as policy guidance. We also do not concur with use of the mitigation to 

turn PEDs off, which is included as an option in several parts of Appendix F, the Avionics 

System Functional Hazard Risk Assessment. 

As mentioned at the outset, commercial air transportation is one of the safest modes of travel 

available, and the Dissenting Group believes adopting the above recommendations to safely 

expand the use of PEDs in flight will continue to ensure this. 

 

                                                            

38 Note that this requirement to turn off and stow PEDs below 10,000 feet AGL is an operational risk‐

based limitation that will allow sufficient time for passengers to comply and crewmembers to perform

compliance checks.
A Report from the PED ARC to the FAA

 Page 32 

Recommendation #10 Method 2: ARC Position 

The PED ARC spent considerable time debating the issues in Table 1 that generated the dissent. 

The majority of the ARC membership voted to retain Recommendation 10, Method 2 and 

respond to the dissenting members’ views as follows: 

Operators should be free to develop an approved phase-of-flight approach to expanded use of 

PEDs. 

The ARC majority believes the expanded use of PEDs should not be an all-or-nothing 

proposition. Operators should be free to develop an approved phase of flight approach in 

Recommendation 10, Method 2 above. Under the recommendations in this report, operators 

would have an opportunity to greatly expand the use of PEDs on board aircraft in almost all 

cases and phases of flight, which is a significant expansion and improvement over today’s 

existing policy and practice. Dictating that expansion could only mean “all phases of flight” 

would deprive passengers of near-term expanded use opportunities on most phases of flight 

when operators could quickly demonstrate aircraft PED tolerance through a Safety Risk 

Assessment or DO-307. Further in response to the dissenters’ views, expanded PED usage 

policies need not be transparent to the flight crews. The ARC majority believes it a reasonable 

workload request for flight crews to turn off navigation aids or make announcements. Operators 

would be free to establish these policies at any convenient point in the flight profile to ensure 

effective work flow in the cockpit. Finally, operators should be allowed to maintain the current 

policy without additional substantiation (i.e., use of PEDs only above 10,000 feet). The majority 

of ARC members believe that sufficient operational experience exists across the industry to 

support the current policy for PED use above 10,000 feet. 

Mitigation of risk by switching off PEDs. 

With the communication strategy outlined in Chapter 9.0 of this report, most ARC members 

believe instructions to switch off PEDs during certain critical phases of flight will remain an 

effective mitigation for both large and small commercial aircraft operators with the right 

messaging. The ARC majority believes that passengers are able to discern phase-of-flight 

restrictions when the reason is properly communicated and explained. Although passenger 

compliance with crewmember instructions is sometimes challenging, as seen with requirements 

for stowage, alcohol and seat belt use for example, passenger compliance with crewmember 

instructions is a core element of airplane travel today. 

Market pressures rather than mandates should drive compliance with DO-307. 

Operators’ desired product offering in the marketplace should drive the decision to use the 

recommended tools –the Safety Risk Assessment and DO-307– to safety expand PED usage to 

the desired phases of flight. A Safety Risk Assessment and full certification to DO-307 are seen 

as potentially very impactful to operators. The possibility of failing any required testing or 
A Report from the PED ARC to the FAA

 Page 33 

discovering unacceptable risks presents unknown costs, recertification burdens and expenditure 

of resources to correct. In general, some aircraft types may be more complex and incur greater 

costs than others in order to comply with a Safety Risk Assessment and DO-307 in order to 

expand PED use to all phases of flight. Even in the cases where operators do not have DO-307-

compliant aircraft, they should not be mandated to complete a Safety Risk Assessment. Given 

the costs and burdens involved, particularly for certain airlines and aircraft, it is best to avoid 

sweeping mandates that could harm operators and instead let market forces drive the decisions 

and related investments of resources. 

Table 1: Summary of the Points of Disagreement 

Issue Dissenters’ Position ARC Position 

Implementation of policy by phase 

of flight 

To avoid passenger confusion, either 

current rules should remain in place, 

or expanded PED use should apply 

to all phases of flight. 

Operators should be free to pursue 

the measures necessary to develop 

an approved phase-of-flight 

approach to expanded use of PEDs. 

Mitigation of risk by switching off 

PEDs 

The efficacy of switching off PEDs 

as an effective mitigation strategy 

will diminish significantly as usage 

expands 

Flight Crew instructions to 

passengers is core to airline 

operations with each airline 

messaging properly to gain 

compliance. Passenger compliance 

to instructions to switch off PEDs 

will not diminish during the phase of 

flight approach with appropriate 

messaging. 

Compliance with DO-307 

Operators must comply with DO307 or acceptable alternative by a 

specified date, which should be 

January 1, 2017. 

There should be a market-oriented 

approach to compliance with DO307 or acceptable alternative that is 

driven by the operator’s own 

decision to safely expand the use of 

PEDs. 
A Report from the PED ARC to the FAA

 Page 34 

7.4 Coordination with the FCC 

The ARC considered the overlap between FAA and FCC regulations and how expanded PED use 

by passengers might be limited by FCC rules. Generally, the FCC imposes emissions limits on 

PEDs and is principally concerned with protecting communications networks and other devices 

from harmful RF interference. In reviewing the information presented by FCC and FAA SMEs, 

the ARC noted that actual PED emissions are typically lower than required by the FCC, and 

generally below DO-160 limits. 

The ARC also noted possible RF interference from airborne PEDs to ground-based networks and 

the relevant FCC rule, 47 CFR Section 22.925, which prohibits airborne use of PEDs operating 

in the 800 MHz band. The ARC determined that it would be appropriate for the FAA to ask the 

FCC whether its prohibition of 800 MHz cell phone use in airplanes remains current, given the 

sophistication of mobile phone networks and the apparent lack of air-to-ground RF interference 

incidents, and despite widespread ignorance of this rule, and whether airborne use of PEDs 

operating in other bands may be permitted. 

Recommendation #11―The ARC recommends that the FAA consult with the FCC with 

regard to Title 47 CFR parts that apply to airborne use of PEDs. 

8.0 OPERATIONAL RECOMMENDATIONS		

The recommendations developed to address operational aspects of PED usage address the 

importance of standardization with regard to stowage of PEDs, enhanced training for airline 

personnel, creation of an effective job aid for operators, and regulatory action by the FAA. 

8.1 Stowage of PEDs 

In discussing concerns raised by passengers about the differences between operator policies, the 

ARC determined that standardization with respect to PED usage and stowage in the cabins of 

commercial airplanes is necessary to enhance the understanding and acceptance of, and 

compliance with, operator policies and federal regulations among passengers and airline/operator 

employees. Standardization will also help to manage crew workloads, such that they are not 

increased by any future changes to PED usage and stowage policies. Appendix G provides 

information for consideration when assessing the impact expanded PED use has on an operator’s 

current stowage policies. 

Recommendation #12―The ARC recommends that the FAA and industry stakeholders 

develop standard content and timing for cabin and flight deck crewmember instructions 

to passengers on use and stowage of PEDs. The development process should include 

testing of the messaging with members of the traveling public. 

Recommendation #13―The ARC recommends that to support standardized industry 

best practices for stowage related to PEDs, the FAA update stowage policy and guidance 

documents to incorporate expanded use of PEDs as necessary.
A Report from the PED ARC to the FAA

 Page 35 

Recommendation #14―The ARC recommends that the FAA work with industry to 

develop a methodology by which exceptions can be granted to PED stowage 

requirements for passengers with special needs (so that they may use devices with 

adaptive or assistive technologies) without compromising safety. 

8.2 Airline Personnel Training 

PED use on aircraft today is growing at an increasing rate. And while the regulations currently 

state that PEDs should be turned off during critical phases of flight, empirically we know that 

devices are being left on. While the majority of passengers say they follow clear and proper 

instructions on PED usage allowed prior to takeoff, the data from recent consumer research 

shows this is not always the case.39 

The following recommendations are provided to improve airline personnel training by 

facilitating better awareness among flight and cabin crews with the expansion of PED use in 

flight, thereby assisting in the validation activity associated with the proposed safety risk 

assessment. 

Recommendation #15―The ARC recommends that the FAA work with industry 

stakeholders to develop consistent and standardized training on the identification of PED 

interference effects so that flight crews are better able to mitigate risks to aviation safety 

and report possible incidents for further investigation as necessary. 

Recommendation #16―The ARC recommends that the FAA work with industry 

stakeholders to develop standardized processes for detecting/observing, reporting, 

evaluating, centralized data storing using existing systems if available, and summarizing 

of incidents, if any, involving adverse Electromagnetic Interference (EMI) effects on 

equipment, as well as passenger noncompliance with PED usage or stowage restrictions. 

Use of these tools should be part of enhanced employee training as proposed by the ARC. 

Recommendation #17―The ARC recommends that the FAA work with industry 

stakeholders to develop model frameworks for training programs targeting crewmembers 

and other affected operator personnel (including management), with minor but necessary 

variations owing to fleet size, airplane configurations and regulatory basis (i.e., part 135 

vs. 121, etc.) utilizing standardized statements. This effort should involve initial and 

recurrent training for all employees, including cabin and flight deck crew, gate agents, 

and other customer service/contact personnel. 

Flight deck, cabin crew, and maintenance personnel should be given training on tools and 

procedures available to them to mitigate the risk of potential EMI. Flight attendants should be 

given training on how EMI can potentially interfere with airplane systems and why some 

                                                            

39 CEA/APEX Survey Data showed 94% of passengers agree the instructions are clear, yet 59% say they always turn 

their devices completely off when asked to do so, with an additional 5% who say they sometimes turn their devices 

completely off. Almost one-third of passengers report they have accidentally left a PED turned on during a flight. 

43% passengers incorrectly believe it is acceptable to use PEDs while taxiing to the runway, 32% while in the air 

before reaching the altitude where PEDs are approved for use and 26% while the plane is in its final descent. (See

Appendix H.
A Report from the PED ARC to the FAA

 Page 36 

restrictions are in place so that they are better prepared to communicate with the travelling 

public. Flight crews and maintenance personnel should be given training on a consistent way of 

reporting, through appropriate maintenance records entry, suspected EMI anomalies so that they 

may be properly diagnosed by maintenance and submitted by the operator to a centralized, deidentified database, which will benefit the industry and the public interest. 

8.3 Creation of a Job Aid for Operators 

The certification/approval path to achieving an expanded use of PEDs can involve the 

understanding and execution of many different RTCA documents, FAA regulations, and 

Inspector Checklists. This task can be overwhelming for an operator with limited resources or 

experience in completing such a large project. The use of a job aid that gives a checklist based 

approach to assist in the implementation of such a program could simplify the process and 

provide a standard way for separate operators to achieve the same approval. This proposed job 

aid would include sections addressing an assessment of airplane PED Tolerance, risks by phase 

of flight, applicable PEDs, and recommendations for implementing operational procedures and 

crew training. 

Recommendation #18―The ARC recommends that the FAA work with industry 

stakeholders to develop a detailed job aid to lead an operator through key items of 

consideration. This job aid should be incorporated in the applicable FAA guidance 

documents. 

8.4 Regulatory Action 

The ARC’s recommendations address various regulatory, policy and safety changes. To support 

these changes, the FAA should document its position on these issues and provide guidance for 

operators to standardize acceptable practices and procedures for operators to decide allowable 

passenger use of PEDs. 

Many recommendations for expansion of use are based on technical determinations that 

determine an acceptable level of risk. Risk determinations can be controversial. There are also 

recommendations that could impact crew procedures, especially for flight attendants. To expand 

PED use, the roles, responsibilities, and assumptions for the flight crews, the operators and the 

regulators must be clearly defined. 

The result of this activity should be coordinated with the international regulatory community to 

harmonize policy and regulations as much as possible. Any change(s) regarding the use of PEDs 

impacts operations not only in the U.S., but worldwide. Differences in policies will confuse the 

flying public and increase the potential for conflict and crew workload. 

Recommendation #19―The ARC recommends that the FAA provide operators with 

policy guidance that institutes the approaches set up in the ARC for expansion of use as 

acceptable methods for compliance with PED use regulations. 

Recommendation #20―The ARC recommends that the FAA establish policy guidance 

for flight crew expectations. This policy should clearly define standardized roles and 

responsibilities for flight crews in the context of expanded PED usage allowance by the 
A Report from the PED ARC to the FAA

 Page 37 

operator. These expectations should lessen the crew’s role in enforcing the PED usage 

policy. 

9.0 SAFETY COMMUNICATIONS RECOMMENDATIONS

In order to address current questions raised by passengers, as well as the questions that will 

likely arise as the operating environment for PEDs evolves, the ARC addressed several issues 

involving the safety communications aspect of expanded PED usage. These recommendations 

speak to the significance of PED terminology and the importance of effective messaging 

regarding PED usage policies. 

9.1 PED Terminology 

In the past, PEDs that transmitted or received radio frequency energy were a small subset of the 

larger population of PEDs. However, the consumer electronics market has evolved to where the 

majority of PEDs incorporate at least one, and frequently more than one, radio technology used 

for communication and data networking. The ARC has generated several recommendations that 

take into consideration the evolving marketplace for these devices. 

Recommendation #21―The ARC recommends that the terminology in FAA 

PED regulations, including 14 CFR 91.21, 121.306, 125.204, and 135.144 be 

updated to remove the outdated references to electronic devices. This 

terminology update should also be applied to all future policy and guidance 

documents. 

Recommendation #22―The ARC recommends the FAA consider (and 

encourage operators to consider) using only the term PED when communicating 

information on operator policy to the public. Based on market data from CEA,

most PEDs carried by passengers today incorporate one or more modes of 

wireless connectivity. With that in mind, distinguishing PEDs as Transmitting or 

Non-Transmitting may be confusing to the general public. 

Recommendation #23―The ARC recommends that the FAA promote and 

encourage airplane operators to establish more stringent policy and guidance for 

PEDs that are not easily accessible to passengers or crewmembers during flight 

operation. Guidelines to PED manufacturers on the test requirements, satisfactory 

test data, and operational characteristics of these devices should be published in 

order to provide operators with an appropriate means to evaluate PEDs for use. 

Examples of these devices include, but are not limited to some medical devices; 

asset tracking devices; data collection and monitoring devices; and devices for 

inventory management. (See Appendix E.) 
A Report from the PED ARC to the FAA

 Page 38 

Recommendation #24―The ARC recommends that the FAA promote and 

encourage airplane operators to develop a common device terminology (e.g., ereaders, smart phones, and tablet computers) when communicating to passengers 

about expanded usage policies. The ARC further recommends implementation of 

this recommendation be completed by November 30, 2013 to minimize confusion 

for the traveling public and allow the operator to clearly state which types of 

PEDs are allowed to be used onboard their airplanes and during which phase(s) of 

flight as outlined in the operator’s usage policy. 

Recommendation #25―The ARC recommends that the FAA encourage the 

airplane operators to provide to passengers lists of PEDs that may not be operated 

in flight, and make such information easily accessible through various media 

including printed material, websites, and audio or visual safety information. 

The public comments also included a proposal to support the expanded use of PEDs during flight 

via a mark that would indicate device compatibility with in-flight usage. The commenter 

correctly recognized that manufacturers in the consumer electronics industry are moving to 

electronic labeling for regulatory compliance and certification marking on devices with displays. 

Under the recommended policy for expanding the use of PEDs during flight, differentiating 

acceptable versus non-acceptable devices with certification or compliance markings, whether 

electronic or not, may be difficult or impossible for crewmembers to observe and verify, and 

susceptible to counterfeiting as well, and would therefore not be useful. 

Neither the FAA nor the FCC should mandate or otherwise encourage testing and/or labeling of 

PEDs as “safe” (from an EMI perspective) for use on airplanes. 

Manufacturers of PEDs should not be prevented from marking or labeling PEDs, electronically 

or otherwise, to indicate compliance with requirements (i.e., DO-160) related to crew or 

passenger use of such PEDs on board airplanes. 

9.2 Communication Regarding PED Usage Policies 

Many passengers today do not understand the reasons for PED usage restrictions on board 

airplanes. For years, passengers have been asked to turn off devices below 10,000 feet. The 

industry should improve its communications to the traveling public such that the safety 

implications of PED usage in flight are clearly understood and accepted. Without standardized, 

consistent messages from the industry, passenger noncompliance will increase, confidence in the 

ability of the FAA and the operators to safely allow expanded use of PEDs will erode, and a 

nonstandard system of operator-dependent policies may emerge that further confuses the public. 

Moreover, public comments indicate the traveling public is aware of PED use by crewmembers, 

which at times may differ from what is permitted for passengers. One example is crewmembers’ 

use of PEDs as Electronic Flight Bags (EFBs). Better understanding of why such differences 

exist would alleviate public confusion in this area. The FAA, operators and other industry 

stakeholders should collaborate to develop information to educate passengers on these 

differences, as well as develop recommendations for training provided to affected 

airline/operator employees. 
A Report from the PED ARC to the FAA

 Page 39 

Recommendation #26―The ARC recommends that the FAA and other stakeholders 

work together to develop messaging designed to better inform the public regarding why 

there would be restrictions on use of PEDs. 

Recommendation #27―The ARC recommends that regulators, industry representatives 

and members of the public collaborate on the development of standardized information 

for travelers, which will be available in multiple, pre-tested formats at ticket purchase, in 

seat-pocket magazines, as well as distributed through various mass media outlets. 

Recommendation #28―The ARC recommends that the FAA, in collaboration with the 

airline industry, explain to the public why there is a difference in PED usage policy for 

crewmembers versus passengers.

Recommendation #29―The ARC recommends that such collaborative efforts include 

programs designed to ensure the validity and efficacy of public messaging, using 

appropriate research, development, testing, evaluation, and feedback processes. In 

addition to the typical methods used for messaging to passengers (e.g., crewmember 

announcements, website and kiosk pop-ups, inflight magazines), the ARC further 

recommends that public information campaigns also leverage social media resources and 

applications to better anticipate and manage public perception and behavior, as well as 

counter misinformation as necessary. 
A Report from the PED ARC to the FAA

 Page 40 

10.0 CONCLUSION

The ARC developed and agreed to the recommendations presented in this report, which address 

expanding the use of PEDs during flight without compromising the continued safe operation of 

airplanes in the national airspace system (NAS). The ARC designed its recommendations to 

allow for phased implementation consistent with stakeholder capabilities, as well as sufficient 

opportunity to engage in a public education campaign concurrent with publication of 

updated/revised guidance and the allowance for expanded PED usage. The members reached 

consensus on 28 of the 29 recommendations included in this report. Five members of the ARC 

dissented to the Method 2 allowance for expanded use of PEDs as set forth in Recommendation 

#10 above, and the dissenting position follows the recommendation. 

The ARC members and their respective organizations appreciated the opportunity to work with 

the FAA in studying the issue of expanding PED usage during all phases of flight and 

formulating recommendations. The ARC appreciates the cooperation and assistance of 

stakeholders from multiple sectors of the aviation industry, as well as the PED manufacturing 

industry, for providing information and data to the members. The members look forward to 

assisting the FAA in implementing the recommendations contained in this final report. 
A Report from the PED ARC to the FAA

Appendices Page A-i 

APPENDICES

APPENDIX A: PED ARC MEMBERS 

APPENDIX B: ABBREVIATIONS & ACRONYMS 

APPENDIX C: PED ARC CHARTER 

APPENDIX D: SAMPLE PASSENGER BRIEFING ANNOUNCEMENT 

APPENDIX E: SHOW COMPLIANCE STANDARD FOR INACCESSIBLE PEDS IN 

FLIGHT 

APPENDIX F: AVIONICS SYSTEM FUNCTIONAL HAZARD RISK ASSESSMENT 

APPENDIX G: PED STOWAGE POLICY ASSESSMENT & CONSIDERATIONS 

APPENDIX H: PASSENGER USE SURVEY DATA 

APPENDIX I: PED INTERFERENCE DATA 

APPENDIX J: PASSENGER NON-COMPLIANCE DATA 

APPENDIX K: INDEX OF REFERENCE DOCUMENTS 

APPENDIX L: GLOSSARY 

 
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Appendix A: PED ARC Members Page A-1 

APPENDIX A:			 PED ARC MEMBERS

Co-Chairs 

Mr. Kirk Thornburg, Industry Chair 

Delta Air Lines 

Mr. Tim Shaver, Designated Federal Official 

Manager, Avionics Maintenance Branch (AFS-360) 

Federal Aviation Administration 

Members and Alternates 

Aerospace Industries Association (AIA) 

Mr. George Novak 

Mr. Cortney Robinson, Alternate Member 

Airline Passenger Experience Association (APEX) 

Mr. Michael Childers, Lufthansa Systems 

Mr. Rich Salter, Lumexis Corporation 

Airbus 

Mr. Peter Anders 

Air Line Pilots Association, International (ALPA) 

Captain Bill de Groh 

Mr. Rick Kessel, Alternate Member

Amazon.com 

Mr. Paul Misener, Technical Subcommittee Chair 

American Airlines 

Mr. Erik Miller 

Association of Flight Attendants-CWA 

Mr. Dinkar Mokadam 

Mr. Christopher Witkowski, Alternate Member 

The Boeing Company 

Mr. David C. Hartze
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Appendix A: PED ARC Members Page A-2 

Cessna Aircraft Company 

Mr. Billy M. Martin

Consumer Electronics Association (CEA) 

Mr. Douglas Johnson, Safety Communications Subcommittee Chair 

European Aviation Safety Agency (EASA) 

Mr. Friedhelm Runge 

Mr. Julian Hall, Alternate Member

Executive Jet Management, (EJM) 

Ms. Michelle A. Schopp 

Federal Aviation Administration 

Ms. Nancy Sanchez 

Mr. Dave Walen 

Federal Communications Commission 

Mr. Julius Knapp 

Garmin 

Mr. Praf Patel 

General Aviation Manufacturers Association (GAMA) 

Mr. Greg Bowles 

Helicopter Association International (HAI) 

Mr. Harold Summers 

JetBlue Airways 

Captain Chuck Cook, Operational Subcommittee Chair 

National Association of Airline Passengers 

Mr. Douglas Kidd 

OnAsset Intelligence 

Ms. Nikki Cuban 
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Appendix A: PED ARC Members Page A-3 

Regional Airline Association (RAA) 

Ms. Stacey Bechdolt 

Mr. Scott Foose, Alternate Member

Rockwell Collins 

Ms. Susan Beard 

Thales Avionics, Inc. 

Mr. Ken Brady 

Transportation Security Administration 

Mr. James Klipp 

Mr. Lee Waller, Alternate Member

FAA Participants & Subject Matter Experts 

Ms. Frankie Berry (AFS-300) 

Ms. Andrea Copeland (ARM-200) 

Ms. D.K. Deaderick (AFS-200) 

Mr. Les Dorr (AOC-100)

Mr. Brian Hint (AFS-430) 

Ms. Marci LaShells (AFS-320) 

Mr. Lee Nguyen (AFS-130) 

Mr. Steve Ramdeen (AIR-100) 

Ms. Monalisa Tindall (AFS-360) 

Mr. Ricky Chitwood (AFS-240) 

Mr. Brian Verna (AFS-360) 

Mr. Bob Warren (AFS-360) 
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Appendix B: Abbreviations and Acronyms Page B-1 

APPENDIX B:			 ABBREVIATIONS & ACRONYMS

Abbreviation/Acronym Definition 

14 CFR Title 14 of the Code of Federal Regulations 

A4A Airlines for America 

AC Advisory Circular 

AFA Association of Flight Attendants 

AFS-200 Air Transportation Division 

AFS-300 Aircraft Maintenance Division 

AGC Office of the General Counsel 

AGCC Aviation Government Coordinated Council 

AIR-100 Aircraft Engineering Division 

ALPA Air Line Pilots Association, International 

AOC FAA Office of Communications 

APEX Airline Passenger Experience Association 

ARC Aviation Rulemaking Committee 

ARM FAA Office of Rulemaking 

ASCC Aviation Sector Coordinating Council 

AVS-1 FAA Associate Administrator for Aviation Safety 

CAA Civil Aviation Authority 

CEA Consumer Electronics Association 

CIPAC Critical Infrastructure Partnership Advisory Council 

CWA Communication Workers of America 

DFO Designated Federal Official 

DHS Department of Homeland Security 

DOT Department of Transportation 

DVD Digital Video Disc 

EASA European Aviation Safety Agency 
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Appendix B: Abbreviations and Acronyms Page B-2 

Abbreviation/Acronym Definition 

EFB Electronic Flight Bag 

EMI Electromagnetic Interference 

FAA Federal Aviation Administration 

FCC Federal Communications Commission 

FM Frequency Modulation 

FOIA Freedom of Information Act 

GAMA General Aviation Manufacturers Association 

GBAS Ground Based Augmentation Systems 

HAI Helicopter Association International 

HIRF High-intensity Radiated Fields 

IATA International Air Transport Association 

ICAO International Civil Aviation Organization 

IEC International Electro-technical Commission 

IEEE Institute of Electrical and Electronics Engineers

NAS National Airspace System 

NASA National Aeronautics and Space Administration 

NIPP National Infrastructure Protection Plan 

PED Portable Electronic Devices 

PPD Presidential Policy Directive

RAA Regional Airline Association 

RF Radio Frequency

RTCA Radio Technical Commission for Aeronautics

SDR Service Difficulty Report

SIG Bluetooth Special Interest Group 

SME Subject Matter Expert 

SMS Safety Management System 
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Appendix B: Abbreviations and Acronyms Page B-3 

Abbreviation/Acronym Definition 

SRM Single-Pilot Resource Management 

SSA Sector Specific Agency(ies) 

TC Transport Canada 

TSA Transportation Security Administration 

TSS Transportation Systems Sector 

TSSGCC Transportation Systems Sector Government Coordinating Council 

VOR VHF Omni Range 

WLAN Wireless Local Area Network 

 
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Appendix C: PED ARC Charter Page C-1 

APPENDIX C:			 PED ARC CHARTER
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Appendix D: Sample Passenger Briefing Annoucement Page D-1 

APPENDIX D:		 SAMPLE PASSENGER BRIEFING ANNOUNCEMENT

Appendix D includes the sample Passenger Briefing Announcement developed by the PED ARC 

Safety Communications Subcommittee. 

The Safety Communications Subcommittee members suggested that the safety briefing for 

passengers that occurs before takeoff be standardized and that it include a statement(s) similar to 

the following, as applicable: 

• “This aircraft has not yet been assessed to tolerate emissions from electronic devices. 

Please power them off until an announcement is made that it is OK to turn them back on 

again.” 

• “This aircraft tolerates emissions from electronic devices for all phases of flight, except 

during certain instrument-only landings, at which time the pilot will restrict usage of 

electronic devices to ensure safety.” 

• “This aircraft tolerates emissions from electronic devices for all phases of flight. Please 

note, however, that the pilot is authorized to restrict use of electronic devices as necessary 

to ensure safe operation of the flight.” 
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Appendix D: Sample Passenger Briefing Annoucement Page D-2 

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Appendix E: Show Compliance Standard for Inaccessible PEDs in Flight Page E-1 

APPENDIX E:		 SHOW COMPLIANCE STANDARD FOR INACCESSIBLE PEDS IN

FLIGHT		

In the case of PEDs that operate in the cabin or cargo areas of the aircraft and are not accessible 

by passengers or crewmembers during flight operation, PED manufacturers should provide 

satisfactory test data and documentation to operators for the determination on whether additional 

aircraft testing is needed. 

Devices that are often not accessible during flight operations include but are not limited to: 

embedded medical devices; data collection and monitoring devices; asset tracking and inventory 

management; and other PEDs that often include connectivity (cellular, Wi-Fi40, Bluetooth41, and 

radio frequency). For the purposes of this section, inaccessible PEDs do not include devices 

stowed by passengers in carry-on baggage intended for personal use. 

The following satisfactory test data and operational characteristics should be provided by the 

PED manufacturer to show PED compliance and safety without the need for operator led 

electromagnetic compatibility testing: 

(1) Satisfactory test report from a properly accredited, independent laboratory for RTCA 

DO-160, Section 21 categories H radiated emissions testing. This testing must include 

the PED configured with any peripheral probes or other attachments that would be used 

during flight operation; 

(2) PED operational characteristics with automated and prolonged radio suspension in 

flight must include multiple modes of redundancy (“automatic airplane mode”) or 

verification that no radio transmitter is used; 

(3) Report containing the operational description, technical specifications, product label, 

and images of the PED and any peripheral attachments; 

(4) Failure Mode and Effects Analysis report (FMEA) of the PED and any peripheral 

attachments; and 

(5) Declaration of stringent design and production controls in place during PED 

manufacturing.

                                                            

40 Wi-Fi is defined as "wireless local area network (WLAN) products that are based on the Institute of Electrical and 

Electronics Engineers' (IEEE) 802.11 standards". Wi-Fi is a trademark of the Wi-Fi Alliance. 41 Bluetooth is managed by the Bluetooth Special Interest Group (SIG). The SIG is the body that oversees the 

development of Bluetooth standards and the licensing of the Bluetooth technologies and trademarks to 

manufacturers. The SIG is a privately held, not-for-profit trade association founded in September 1998. 
A Report from the PED ARC to the FAA

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Appendix F: Avionics System Functional Hazard Risk Assessment Page F-1 

APPENDIX F:		 AVIONICS SYSTEM FUNCTIONAL HAZARD RISK ASSESSMENT		

Appendix F includes the complete Avionics System Functional Hazard Risk Assessment 

developed and documented by the PED ARC Safety Assessment Working Group, as submitted 

to the PED ARC on September 16, 2013. 
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Appendix F: Avionics System Functional Hazard Risk Assessment Page F-3 

Portable Electronic Device (PED) Aviation Rulemaking Committee 

Avionics System Functional Hazard Risk Assessment 

Summary 

The ARC has determined that in order to expand PED use to certain phases of flight, an 

assessment of the risks must be made. To assist operators in making the safety 

determination, the FAA will develop a risk assessment based on the information and 

data available at this time. This paper outlines the approach used to establish the safety 

risk assessment, documents the assumptions and provides operators with a base lined 

risk assessment that they can use when developing their PED allowance usage policy. 

 

FAA/AFS-360 

September 25, 2013 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-4 

Contents

1. Background F-5 

2. Acknowledgement F-5 

3. System Functional Hazard Risk Assessment F-5 

4. Hazard Identification F-6 

5. Risk Analysis F-26 

6. Likelihood Assessment F-27 

7. Risk Acceptance. F-28 

8. Decision Making F-29 

9. Validation F-30 

10. Conclusion F-31 

Appendix 1

Predicted Residual Risk - Transmitting PED “Back Door” Interference F-33 

Appendix 2

Systems Hazard Assessment by Phase of Operations F-37 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-5 

1. Background

1.1. During its deliberations, the ARC recommended that the FAA conduct a safety 

management system (SMS) risk assessment and engage safety experts on its staff 

and across industry to look for hazards associated with PED interference potential. 

1.2. While the PED ARC membership included some system expertise to identify 

hazards, the ARC suggested that a more focused group could develop a complete 

list of hazards, assessed to SMS standards. 

1.3. To support expanded PED use recommendations proposed by the ARC, this safety 

risk assessment was accomplished to assist the operators when determining if 

expanded use of PEDs is acceptable for their aircraft and operations. 

1.4. This assessment looks at the technical risks associated with PED induced failures to 

avionics systems. It is intended to be used as a tool in conjunction with other 

operational considerations. Considerations such as PED stowage, crew and 

passenger education, or other operational issues must be addressed when 

expanding passenger use of PEDs to other phases of flight. 

1.5. This assessment reviews the avionics systems and functions that were available and 

prevalent at the time of the review. 

2. Acknowledgement

The ARC Chair thanks the numerous FAA and industry experts that performed initial 

research and contributed information for this study. Additionally, we would like to 

recognize the contributions of the following individuals who have volunteered their 

significant time and expertise to this effort: 

Captain Chuck Cook, JetBlue 

Richard Jennings, FAA 

Rick Kessel, ALPA 

Billy Martin, Cessna 

Erik Miller, American Airlines 

Michelle Schopp, EJM 

Tim Shaver, FAA 

Brian Verna, FAA 

Dave Walen, FAA 

3. System Functional Hazard Risk Assessment

This assessment is broken down into six basic areas of consideration. 

• Hazard identification - Identify hazards and consequences 

• Risk analysis - Analyze hazards and identify risks 

• Risk assessment - Consolidate and prioritize risks 

• Likelihood Assessment - Assess probability 

• Decision making - Identify mitigations and controls; and 

• Validation - Evaluate results for further action. 
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Appendix F: Avionics System Functional Hazard Risk Assessment Page F-6 

4. Hazard Identification		

4.1. This assessment identifies and classifies functional failure conditions associated 

with the operation of the aircraft systems, with a hazard classification of major and 

above. These functional failure conditions are placed into two categories based on 

the types of interference coupling mechanisms to which the systems are 

susceptible. For the purpose of this assessment, those categories are “front door” 

coupling and “back-door” coupling to the susceptible systems. 

To address these problems, in 2003 the FAA tasked RTCA42 with development of 

design certification standards to ensure that aircraft systems would tolerate PED 

emissions. These design standards ensure the coupling paths are at the level to 

ensure protection from both front door and back door emissions. 

Assumption: Aircraft systems that comply with the design tolerance 

requirements established in RTCA DO-307 as discussed in FAA 

Advisory Circular (AC) 20-164 need no further systems level 

functional hazard safety risk analysis. 

4.2. Back Door Coupling 

Intentional RF emissions from transmitting portable electronic devices have the 

potential to interfere with aircraft electrical and electronic systems by the emitted 

signal coupling to cables or directly into the aircraft system equipment. The potential 

for interference depends on the strength of the PED transmitted signal, and the 

aircraft system susceptibility at the specific frequency of the PED transmission. 

4.2.1. Some aircraft electrical and electronic systems are protected against the effects 

of electromagnetic interference, particularly against high intensity radiated fields 

(HIRF), and both the direct and indirect effects of lightning. The system tolerance 

to RF fields depends on the system criticality and its location in the aircraft. The 

aircraft system HIRF and lightning protection provide sufficient immunity to the 

back door effects of PEDs43. 

4.2.2. Since 1986, the FAA has required compliance to the HIRF requirements, 

implemented through special conditions. This history of the application of HIRF 

requirements is explained in the preamble of the 2006 notice of prosed 

rulemaking44. HIRF special conditions were applied to systems whose failure or 

malfunction would prevent continued safe flight and landing of the aircraft. The 

majority of aircraft certified since 1989 were also certified to the JAA/EASA 

special conditions, which required compliance to Major, Hazardous and 

Catastrophic failure conditions, in similar fashion to the existing rule. 

 

                                                            

42 RTCA DO‐307 “Aircraft Design and Certification for Portable Electronic Device (PED) Tolerance” and AC 20-164 

“Designing and Demonstrating Aircraft Tolerance to Portable Electronic Devices”.

43 See RTCA DO‐307 “Aircraft Design and Certification for Portable Electronic Device (PED) Tolerance”, paragraph

2.2.3 for further discussion. 44  See Docket No. FAA‐2006‐23657, Notice No. 06‐02 for full information.  Available at www.regulations.gov
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-7 

4.2.3. The risk analysis accomplished in Appendix 1 provides information about the 

protections provided by HIRF requirements and the residual risk factors for backdoor interference. 

Assumption: Critical aircraft systems in the analysis included in Appendix 1 

is assumed to meet the design High Intensity Radiated Field 

(HIRF) design criteria and therefore are not susceptible to Backdoor interference. Refer to the aircraft Type Certificate Data 

Sheet (TCDS) for the certification basis at the original date of 

manufacture, a list of the applicable certification regulations, 

and Special Conditions compliance. 

4.2.4. Some aircraft have wireless connectivity systems installed for passenger use. 

During certification of these systems, specific tests were performed to ensure 

that back-door interference from PEDs communicating with the wireless 

connectivity system does not occur. Those tests are defined as part of an issue 

paper. See FAA AC 20-166 “Issue Paper Process” for more details on issue 

papers used during the wireless system certification. The tests use a portable 

wireless IEEE 802.11a/b/g/n transmitter emulator consisting of a signal 

generator, amplifier and transmitting antenna. The radiated power of the 

emulator is 36 dBm (4 watts) EIRP. The emulator antenna is positioned 

throughout the airplane cabin and flight deck including positions at cabin seats, 

aisles, galleys, crew rest areas, lavatories and the cockpit or flight deck. During 

the tests, all aircraft systems that are Required by regulations (such as 

flight/cockpit recorders), or have Major, Hazardous and/or Catastrophic, failure 

conditions (such as primary flight displays and electronic engine controls, etc.) 

are monitored to ensure proper performance. This emulation test does not take 

place of HIRF or DO-307 certification which requires testing across a much wider 

frequency spectrum. However, it ensures that the maximum expected power 

levels from the normal T-PED systems will not introduce back-door interference 

to the critical systems when operated. The operator must accomplish a review of 

the data used during wireless connectivity system certification and verify that the 

testing shows that the systems critical to the expanded phase of flight were PED 

tolerance tested. The operators may use that to support their PED allowance 

determinations for those flight phases. 

Assumption: Aircraft systems with major, hazardous and catastrophic failure 

conditions that have been tested during certification of wireless 

system installations and found to comply with backdoor 

interference requirement may use that testing in lieu of DO-307 

certification as applicable. 

Note: At the time of this writing, use of cellular technology is 

prohibited in flight per FCC regulations. If the operator intends 

to use cellular technology in flight, or if the operational 

environment changes in such a way that cellular use becomes 

prevalent, then additional testing of aircraft systems may need to 

be accomplished for back door interference effects. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-8 

4.3. Front Door Coupling 

4.3.1. This type of interference coupling mechanism occurs in the operational band of 

the avionics receivers. The spurious emissions from PEDs received by the 

aircraft radio receiver antennas can potentially interfere with aircraft radio 

receivers. 

4.3.2. Current PED production specifications tend to increase front door effect safety 

margins (decrease probability of PED interference) due to a reduction in both 

power output and unintentional (spurious) emissions from PEDs. There are 

several reasons for this: 

• Miniaturization of the electronics to save power. 

• Large reduction in power consumption in the non-active state, driven 

primarily by the desire to extend battery life. 

• Current prevalent PED design incorporates multiple transmitters within the 

same unit, which requires isolation and drives a reduction of spurious 

emissions to ensure compatibility within the unit itself. 

• Typical consumer PED design tends to be characterized as ‘digital’, rather 

than ‘analog’, which reduces the broadband emissions when compared to 

older electronic devices. Devices that contain certain design elements like a 

motor or DC-DC converter (e.g. CD players, older robotic toys) could 

produce fairly significant emissions and introduce a front door coupling 

issues. 

In addition, many of the same mitigations given for PEDs are also applicable to 

modern avionic systems, which are becoming much more digital in design. These 

systems (though still susceptible to front door effects, such as the broadband, 

spurious emissions prevalent in PEDs, that could possibly degrade or undermine 

the availability of the function) are much less susceptible to the front door effects 

that would result in “misleading information” which is generally accepted as the 

greatest threat presented by the PEDs to the safety of the aircraft. 

4.3.3. This assessment establishes severity classifications based on the level required 

for system installation certification. The severity classifications provided in this 

analysis were established using the Functional Hazard Assessment (FHA) of 

several aircraft and avionics manufacturers, as well as other FAA operational 

safety assessments and FAA advisory circular guidance materials. These 

included both large transport airplanes certificated under 14 CFR Part 25 and 

smaller airplanes certificated in the normal and commuter categories. 

A FHA is conducted at the beginning of the aircraft/system development cycle. It 

identifies and classifies the failure condition associated with the aircraft functions 

and combinations of aircraft functions. These failure condition classifications 

establish the safety objectives and are the means used by the manufacturers to 

define design requirements and develop a system architecture capable of 

meeting the requirements of 14 CFR 25.1309. The FHA process ensures that 

the required design features and operational aspects are provided in the finished 

aircraft or avionics system design. 

A system level FHA is also a qualitative assessment which is iterative in nature 

and becomes more defined as the system evolves. It considers a failure or 

combination of system failures that affect an aircraft function 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-9 

In order to make this approach applicable to as broad a range of applications as 

possible, the assessment accomplished in this report builds upon existing FHAs 

by reviewing the system failure modes with respect to a ‘front door’ interference 

event potentially introduced with the expansion of PED use, and assesses the 

operational effect of the failure mode in various phases of flight. 

In general, broadband PED spurious emissions with noise-like characteristics 

increase the noise floor of the affected aircraft radio receivers, distorting low level 

desired signals until they are no longer usable. This effectively increases the 

level of the desired signal necessary for proper communication or guidance, 

decreasing the maximum operating range for the aircraft radio system. Narrow 

band spurious emissions from PEDs with continuous wave (CW) characteristics 

can also be received by the aircraft radio receivers and detected as a valid 

signal, resulting in erroneous responses from system receivers. Broadband 

spurious emissions are likely to be more of a threat than narrowband emissions 

which require a worst-case combination of conditions to affect the avionics 

receivers. Relevant avionics system failure modes can be classified into three 

basic categories. 

• Denial of service – This failure condition prevents the avionics receiver 

system from receiving the desired signals rendering the system 

functionally inoperative. 

• Degradation of service - This failure condition inhibits the avionics 

receiver system from optimal performance. In some instances the 

accuracy of the system may be degraded. In others, the system’s 

receiver range may be degraded. 

• Misleading information – This failure condition causes the system to 

provide misleading information without introducing a system failure and 

may not be obvious to the crew. 

PED interference that introduces these failure modes are an occurrence whose 

origin is distinct from the airplane. These are produced as an unintended 

consequence of PED usage. 

Note: The failure modes used in this analysis are not intended to 

cover intentional interference, malicious intent or sabotage. 

Each avionics receiver system has been evaluated to determine the impact these 

failures could have on the system. Like HIRF, system architecture such as 

placement of receiver system antennas, could result in common cause failures. 

These common cause events or failures can bypass or invalidate redundancy or 

independence of some systems. This analysis considers common cause failures 

when reviewing potential mitigation and controls. 

   
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Appendix F: Avionics System Functional Hazard Risk Assessment Page F-10 

4.3.4. Avionics Receiver System Analysis

4.3.4.1. ADF, HF and HF Datalink

The ADF, HF voice, and HF datalink radios, which operate at frequencies 

below 30 MHz, have been determined in RTCA DO-294 and DO-307 to have 

sufficient protection from PED emissions and does not require further 

analysis. This is because the physics of PED emissions in these frequency 

ranges preclude meaningful emissions at these frequencies. Since PEDs are 

physically small, they cannot radiate frequencies with wavelengths 

significantly larger than the dimension of the PED. For example, the 

wavelength of the upper frequency range of the HF voice transmitter (30 

MHz) is 10 meters, resulting in a quarter wavelength of 2.5 meters and onetenth wavelength (where radiators begin to act as transmission lines) of 1 

meter, which is much larger than the typical PED. 

4.3.4.2. Marker Beacon

The Marker Beacon system has been determined in RTCA DO-294 and DO307 to have sufficient protection from PED emissions and does not require 

further analysis. This is because the statistical PED emissions reported in 

RTCA DO-307, Table 4-5 are already significantly lower than the aggregate 

receiver interference threshold. Thus, the Marker Beacon system is not 

affected by PED-induced spurious emissions. 

4.3.4.3. Instrument Landing Systems (ILS)

4.3.4.3.1. Localizer45 - The Localizer (LOC) provides a reference signal aligned 

with the runway centerline and deviation signals when the airplane is 

displaced left or right of the extended runway centerline. The linear 

coverage area for this signal is approximately 3 degrees either side of 

the extended runway centerline from a point emanating at the far end 

of the runway. The LOC data are displayed to the crew on the 

primary flight displays. 

The localizer transmitter operates on one of 40 ILS channels within 

the frequency range of 108.10 to 111.95 MHz. The signal transmitted 

by the localizer consists of two vertical fan-shaped patterns that 

overlap, at the center. They are aligned with the extended centerline 

of the runway. The right side of this pattern, as seen by an 

approaching aircraft, is modulated at 150 Hz . The left side of the 

pattern is modulated at 90 Hz. The overlap between the two areas 

provides the on-track signal. 

The width of the navigational beam may be varied from approximately 

3o to 6o, with 5o being normal. It is adjusted to provide a track signal 

approximately 700 ft wide at the runway threshold. The width of the 

beam increases so that at 10 NM from the transmitter, the beam is 

approximately one mile wide. 

 

                                                            

45 RTCA/DO‐195, Minimum Operational Performance Standards for Airborne ILS Localizer Receiving

Equipment Operating within the Radio Frequency Range of 108‐112 MHz, Prepared by SC‐153, November 17,

1986.
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-11 

With special authorization, the localizer system can be also used 

for low visibility take-off guidance. Operators may be authorized 

takeoff minimums with a visibility of 300 feet runway visual range 

(RVR). For these operations, the airport ground localizer 

equipment must meet stringent requirements. The airport facility 

must also have certain equipment installed and operating. These 

include taxiway lead-on lights serving the takeoff runway; at least 

two RVR sensors and High Intensity Runway Lights (HIRL). 

Note: This assessment does not address low visibility localizer 

take-off operations. If an operator chooses to allow PED use 

during these operations, they must assess the associated 

risks. The failure modes for the localizer function remain the 

same as in this assessment, however the hazard levels for 

the failures were not available when this assessment was 

completed and must be determined. 

4.3.4.3.2. Glide Slope46 The ILS glide slope provides a vertical flight path 

(nominally 3 degree descent angle) to a point in the landing zone 

of the runway. The vertical coverage is approximately 0.7 

degrees on either side of the vertical reference path. The GS data 

is displayed to the crew on the primary flight displays. The GS 

signal is transmitted on a carrier frequency using a technique 

similar to that for the localizer. The center of the glide slope signal 

is arranged to define a glide path of approximately 3° above 

horizontal (ground level). The beam is 1.4° deep (0.7° below the 

glide-path center and 0.7° above). 

The ILS glide slope is produced by a ground-based UHF radio 

transmitter and antenna system, operating at a range of 329.30 

MHz to 335.00 MHz and is also modulated with 90 Hz and 150 Hz 

tones, with a 50 kHz spacing between each channel. The 

transmitter is located 750 to 1,250 feet (ft) down the runway from 

the threshold, offset 400 to 600 ft from the runway centerline. 

The pilot (or the autopilot) controls the aircraft so that the glide 

slope indicator remains centered on the display to ensure the 

aircraft is following the glide path to remain above obstructions 

and reach the runway at the proper touchdown point (i.e., it 

provides vertical guidance). 

 

                                                            

46 RTCA/DO‐192, Minimum Operational Performance Standards for Airborne ILS Glide Slope Receiving

Equipment Operating within the Radio Frequency Range of 328.6 – 335.4 MHz, Prepared by SC‐153, July 19,

1986
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-12 

4.3.4.3.3. EMI Failure Modes – Because of the type of signal transmitted by 

the ILS, the applicable failure modes are denial of service, 

degradation of service and misleading information. The operation 

of the ILS system usually requires the antennas for redundant 

systems (when installed) to be located in close proximity. Due to 

antenna placement, it is possible that redundant ILS systems may 

suffer simultaneous interference events (common mode failures). 

Denial of service is similar to an inoperative localizer ground 

station. The interfering PED(s) would prevent the aircraft system 

from receiving the desired signal. The aircraft system would 

indicate or “flag” this failure to include blanking of the ILS 

indication of the displays. 

Degradation of service is very similar to denial of service. The ILS 

system may or may not indicate a failure flag, and may appear as 

though the reference signal is too weak to be received (i.e. out of 

range). A momentary flag, or brief needle deflections, or both, may 

occur. This is similar to when obstructions or other aircraft pass 

between the transmitting antenna and the receiving aircraft. 

Misleading information is when the aircraft system is affected by 

PED interference in such a way that the system displays the 

incorrect information. The ILS data is used by the flight director 

displays and autopilot to guide the aircraft on final approach. 

When used for a coupled autopilot approach, ILS signals 

autonomously control the flight path of the airplane. EMI induced 

dithering of ILS position data during coupled approach operations 

could cause erratic aircraft motion and/or the aircraft to be 

improperly positioned during the approach. 

The localizer and glide slope receivers are susceptible to noiselike interference and to single-frequency continuous wave (CW) 

interference from PED emissions. The localizer and glide slope 

receivers detect signals in 90 and 150 Hz sidebands around the 

carrier frequency and provide guidance signals based on the 

amplitude ratio for the 90 and 150 Hz sidebands. Noise-like 

interference and CW interference result in errors in the indicated 

guidance signals. CW interference can also result in the receiver 

locking on to the interfering signal instead of the intended carrier 

signal, again resulting in indicated guidance signal errors. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-13 

4.3.4.3.1. EMI Failure Effects – The failure effects associated with ILS 

systems are listed in Appendix 2, table reference number 1.00. 

The failure condition classification (defined in section 4 of this 

document) of the ILS systems functions range minor effects to 

catastrophic effects depending on the usage and level of 

integration with other systems. 

4.3.4.4. VHF Omnirange47 (VOR)

4.3.4.4.1. A VOR is a ground-based electronic navaid transmitting 360° 

azimuth signals on assigned carrier frequencies ranging from 

108.0 to 117.9 MHz. The VOR uses a reference signal and a 

variable signal to transmit the bearing information. The reference 

signal is a 30 Hz signal radiated omnidirectionally in 360 degrees 

of azimuth with a constant phase. The variable signal is also a 30 

Hz signal which rotates around the ground station at a set speed 

(varies depending on type of VOR) and the signal phase varies 

with respect to direction of transmission. 

In the composite VOR signal, the carrier is transmitted from one 

antenna and the sidebands are transmitted from a separate 

antenna. In space these two signals will produce an amplitude 

modulated signal. A 9960 Hz sub-carrier frequency is deviated by 

+ or – 480 Hz at a 30Hz rate. Then the frequency modulated subcarrier is amplitude modulated on the carrier. Radial information 

is derived from the difference in time between the two signals. 

The resulting phase difference is used by the airborne equipment. 

The VOR function and display varies. An Omni-Bearing Indicator 

(OBI) is the traditional VOR indicator used in general aviation. It 

consists of a knob to rotate an "Omni Bearing Selector" (OBS), 

and the OBS scale around the outside of the instrument, used to 

set the desired course. The display’s “course deviation indicator" 

(CDI) is centered when the aircraft is on the selected course, or 

gives left/right steering commands to return to the course. A TOFROM indicator shows whether following the selected course 

would take the aircraft to, or away from the station. On electronic 

displays, the Horizontal Situation Indicator (HSI) combines 

heading information with the navigation display. 

 

                                                            

47 RTCA/DO‐196, Minimum Operational Performance Standards for Airborne VOR Receiving Equipment Operating

within the Radio Frequency Range of 108‐117.95 MHz, Prepared by SC‐153, November 17, 1986
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-14 

In addition to traditional en route and approach navigational 

functions provided by direct use of VOR, its use has also been 

incorporated into various flight management systems (FMS) as a 

method to update the position accuracy of these systems. The 

FMS Area Navigation (RNAV) function provides navigation display 

based on the system’s navigation database. Typically, position 

updates from at least two VOR stations, or one VOR/DME station 

is required by these systems to indicate the aircraft position on a 

moving map, or display course deviation relative to a waypoint 

(virtual VOR station). 

4.3.4.4.2. EMI Failure Modes – Because of the type of signal transmitted by 

the VOR, the applicable failure modes are denial of service, 

degradation of service and misleading information. The operation 

of the VOR system usually requires the antennas for redundant 

systems (when installed) to be located in close proximity. Due to 

antenna placement, common mode failures for this system are 

possible. 

Denial of service is similar to an inoperative VOR ground station. 

The interfering PED(s) would prevent the aircraft system from 

receiving the desired signal. The aircraft system would indicate or 

“flag” this failure to include blanking of the VOR indication of the 

displays. 

Degradation of service is very similar denial of service. The VOR 

system may or may not indicate a failure flag, and may appear as 

though the reference signal is too weak to be received (i.e. out of 

range). A momentary flag, or brief needle deflections, or both, may 

occur. 

Misleading information is when the aircraft system is affected by 

PED interference in such a way that the system displays the 

incorrect information. The VOR data is used by the flight 

management system or traditional indicator to provide navigational 

direction to the pilots. EMI induced dithering of VOR position data 

during operation could cause the aircraft to be improperly position 

for navigation or non-precision approach. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-15 

The VOR receivers are susceptible to noise-like interference and 

to single-frequency continuous wave (CW) interference from PED 

emissions. The VOR systems detect the variation in signal phase 

and time to determine the correct course for the system. Noiselike interference and CW interference result in errors in the 

indicated guidance signals. CW interference can also result in the 

receiver locking on to the interfering signal instead of the intended 

carrier signal, again resulting in indicated guidance signal errors. 

4.3.4.4.3. EMI Failure Effects – The failure effects associated with VOR 

systems are listed in Appendix 2, table reference 2.00. The failure 

condition classification (defined in section 4 of this document) of 

the VOR systems functions range minor effects to hazardous

effects depending on the usage and level of integration with other 

systems. 

4.3.4.5. VHF Comm (including Voice and VDL Modes, 2 and 3)

4.3.4.5.1. VHF Communication 

Very High Frequency Communication is the standard civil aviation 

short range communication system. VHF Comm operates in the 

frequency band from 118.000 MHz to 137 MHz. VHF is used by 

ground control facilities and aircraft or by aircraft and other aircraft on 

one of 760 possible frequency channels with 25 kHz spacing between 

channels. Current International Civil Aviation Organization (ICAO) 

regulations require VHF channel spacing of 8.33 kHz. This expands 

the number of available VHF channels to 2280. Another VHF service 

available is weather information transmitted from ground stations. 

VHF uses line of sight space wave transmissions with a theoretical 

range of 123 miles between an aircraft at a height of 10,000 ft and a 

ground station at sea level. In practice, however, useable range will 

also vary depending upon factors such as transmitter power, receiver 

sensitivity, atmospheric and temperature conditions, ground station 

geographical situation, and any obstruction in between aircraft and 

ground station (i.e. mountains, hills and trees). As a general rule, 

satisfactory two-way communication can typically be maintained up to 

200 miles dependent on the aircraft height. 

The principle operations of VHF voice and data systems are divided 

into three categories; Air Traffic Services (ATS), Aeronautical 

Operational Control (AOC), and Aeronautical Administrative 

Communications (AAC). ATS and AOC are services required for the 

safety and regularity of flight. AAC messages are associated with the 

airline commercial management communications. 

VHF Voice Comm radio operations use amplitude modulation, 

predominantly, double sideband modulation of the assigned VHF 

carrier frequency for voice communication. Four VHF channels, 

136.900, 136.925, 136.950, and 136.975 MHz are reserved for data 

communications worldwide. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-16 

VHF Digital Link (VDL) has defined standards for VDL Modes 2-4 

which provide different capabilities. VDL Mode 2 operation is 

based on the Carrier Sense Multiple Access (CSMA) scheme to 

support data link compatibility. VDL Mode 3 allows simultaneous 

voice and data link capability using the Time Division Multiple 

Access (TDMA) architecture. 

A VDL Mode 2 CSMA transmitter uses feedback from the receiver 

to determine whether another transmission is in progress before 

initiating a transmission. If a carrier is sensed, the station waits for 

the transmission in progress to finish before initiating its own 

transmission. The VDL Mode 2 uses a 25 kHz spaced VHF 

channel of a modulation scheme called Digital 8-Phase Shift 

Keying (D8PSK) providing a data rate of 31.5 kilobit/second. This 

is the highest data rate that can be achieved in a 25 kHz channel 

with a maximum range of 200 nautical miles. This required the 

implementation of VHF digital radios. 

VDL Mode 3 uses the D8PSK modulation scheme and the TDMA 

media access control scheme. VDL Mode 3 allows for functionally 

simultaneous voice and data link. 

4.3.4.5.2. EMI Failure Modes – Because of the type of signal transmitted by 

the VHF Comm, the applicable failure modes are denial of service 

and degradation of service. Misleading information is not 

considered a viable failure mode. The VHF antennas are installed 

at various locations on the aircraft, typically not in close proximity. 

This significantly decreases the likelihood of common mode 

failures. 

Denial of service for VHF Comm can occur in basically two ways. 

For voice communications, EMI can cause audible tone 

interference at a high enough level that desired communication 

voice reception may become completely unintelligible. For voice 

and data communications, the interfering signal can also block the 

receipt of the tuned channel. 

Degradation of service is very similar to denial of service. For 

voice communications, EMI induced audible tone interference 

occurs at a lower level or intermittently at a higher level, rendering 

desired voice communication reception difficult. For data 

communications, the interfering signal can also block or corrupt 

the receipt of messages. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-17 

Misleading information is not considered a viable failure mode. 

VHF Comm voice and data services provide audible and visual 

data to the pilots. EMI interference cannot introduce audible or 

data communications that are contrary to what is intended. While 

it may be argued that loss of individual parts of a voice string or 

blockage of individual data messages could result in 

misunderstanding of the desired communication, these faults are 

caused by denial or degradation of the receipt of the intended 

signal, not as a result of introduction of misleading information. 

4.3.4.5.3. EMI Failure Effects – The failure effects associated with VHF 

Comm systems are listed in Appendix 2, table reference 3.00. 

The failure condition classification (defined in section 4 of this 

document) of the VHF Comm systems functions range from minor

effects to major effects depending on the number of 

communication systems are affected and the ability of the crew to 

select and use another communications system. 

4.3.4.6. Distance Measuring Equipment (DME) 

4.3.4.6.1. DME is a radio aid for short and medium-distance navigation. It is a 

secondary type of radar that allows several aircraft to simultaneously 

measure their distance from a ground reference (DME transponder). 

The distance is determined by measuring the propagation delay of a 

radio frequency (RF) pulse that is emitted by the aircraft transmitter 

and returned at a different frequency by the ground station. 

The DME provides distance to a runway when the DME is collocated 

with an ILS station. En route or terminal area distance information is 

provided when a DME is collocated with a VOR. 

DME equipped aircraft transmit encoded interrogating pulse pairs on 

the beacon's receiving channel. The beacon replies with encoded 

pulse pairs on the airborne equipment’s receiving channel, which is 

63 MHz apart from the beacon’s channel. The DME transmits and 

receives in the range 962-1213 MHz. The transmitted pulses are 

paired 12 μsec apart, each pulse lasting 3.5 μsec. The pulse-pair 

repetition rate ranges from 5 to 150 pulse pairs per second. 

The interval between the interrogation emission and the reply 

reception provides the aircraft with the slant range information from 

the ground station; this information displays on the cockpit indicator. 

The aircraft’s receiver receives and decodes the transponder’s reply. 

Then it measures the lapse between the interrogation and reply and 

converts this measurement into electrical output signals. The beacon 

introduces a fixed delay, called the reply delay, between the reception 

of each encoded interrogating pulse pair and the transmission of the 

corresponding reply. 

   
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-18 

The transponder periodically transmits special identification pulse 

groups that are interwoven with the reply and squitter pulses; the 

aircraft decodes these special pulses as Morse tones keyed with 

the beacon code identification. 

4.3.4.6.2. EMI Failure Modes – Because of the type of signal transmitted by 

the DME system, the applicable failure modes are denial of 

service and degradation of service. Misleading is not considered 

as a viable failure mode. The DME systems may be susceptible 

to both broad and narrow band PED interference emissions. The 

antennas for redundant systems (when installed) are usually 

located in close proximity. Due to antenna placement, common 

mode failures for this system are possible. 

Denial of service is similar to an inoperative DME system. The 

interfering PED(s) would prevent the aircraft system from 

receiving the desired signal. The aircraft system would lose the 

distance indication and may or may not indicate or “flag” this 

failure. 

Degradation of service shares some of the same failures denial of 

service. The DME system would experience data dropout and no 

replies to a portion of the interrogations. The PED interference 

may cause individual data dropouts caused by disruption to the 

received pulse signals. The system may or may not indicate an 

intermittent failure flag. 

Misleading information is not considered a viable failure mode. 

The information used by DME systems consist of pulsed pairs that 

vary in both time and frequency. The aircraft’s receiver uses a 

stroboscopic technique to recognize the replies to its own 

interrogations among the many other pulses transmitted by the 

beacon. Each reply to a DME interrogation is offset in time by 

50ms. The distance to the station is then derived by determining 

the signal in space transmission time between the interrogation 

and the reply paired pulses. In order for a PED EMI to cause 

misleading information, it would have to introduce a random 

combination of pulses that are the same shape and frequency of 

the intended signal. The introduced pulse then would have to be 

timed with the receipt of the interrogation replay. Finally, the 

timing of the pulsed paired separation would have to correlate with 

the specific equation that would cause the system to indicate 

consistent distance information. The probability for this type of 

failure to occur is so extremely low that this failure mode is not 

considered viable. 

4.3.4.6.3. EMI Failure Effects – The failure effects associated with DME 

systems are listed in Appendix 2, table reference 6.00. The failure 

condition classification (defined in section 4 of this document) of 

the DME systems functions are minor effects. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-19 

4.3.4.7. Transponder Systems

The avionics transponder systems include Mode A/C Transponder 

Receiver; Mode S Transponder Receiver systems; Universal Access 

Transceiver (UAT) and Automatic Dependent Surveillance Broadcast 

(ADS-B) 

4.3.4.7.1. Mode A/C Transponder - The Mode A/C Air Traffic Control Radar 

Beacon System (ATCRBS), is a secondary surveillance radar 

system developed for use within the air traffic control system for 

more precise position reporting of planes. It is used in conjunction 

with the primary radar, to determine the presence of planes in the 

airspace. ATCRBS supplements this positional information with 

positive identification and altitude information, allowing controllers 

to track each plane more precisely and efficiently. 

The ATCRBS system is an interrogation-based system that is 

comprised of a ground-based interrogator and an on-plane 

transponder. On the ground, an ATCRBS sensor sends out an 

interrogation signal (using the 1030 MHz frequency band) from a 

rotating antenna to aircraft flying in its sector. Aircraft that are 

equipped with transponders receive these interrogations and send 

back a reply (using the 1090 MHz band). There are two primary 

types of interrogations; Mode A interrogations are used for plane 

identification information, and Mode C interrogations are used for 

altitude information. 

4.3.4.7.2. Mode S Transponder - The Mode S transponder provides the 

functions of existing ATCRBS transponders; (Modes A and C; 

identification and altitude reporting) but because of its design 

characteristics, is able to do so in a more efficient manner. 

Each interrogation contains the unique address of the aircraft for 

which it is intended. A Mode S transponder receiving an 

interrogation examines it for its own address. If the address 

corresponds, the transponder generates and transmits the 

necessary reply; all other aircraft ignore the interrogation. 

This type of interrogation management ensures that no 

overlapping replies arrive at the interrogator's antenna and 

prevents random replies from interrogators with overlapping areas 

of coverage. This technique improves Secondary Surveillance 

Radar (SSR) performance and increases system capacity. 

The operation of Mode S transponders by the flight crew is 

identical to conventional transponders (ATCRBS). The Mode S 

transponder is required for TCAS II operation. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-20 

4.3.4.7.3. Universal Access Transceiver - A Universal Access Transceiver 

(UAT) refers to a data link that operates on a frequency of 978 

MHz intended to serve the majority of the general aviation 

community. UAT system supports Automatic Dependent 

Surveillance Broadcast (ADS-B), Flight Information Service – 

Broadcast (FIS-B) and Traffic Information Service - Broadcast 

(TIS-B). 

UAT will allow aircraft equipped with "out" broadcast capabilities to 

be seen by any other aircraft using ADS-B In technology as well 

as by FAA ground stations. Aircraft equipped with ADS-B In 

technology will be able to see detailed altitude and vector 

information from other ADS-B Out equipped aircraft as well as 

FIS-B and TIS-B broadcasts. The FIS-B broadcast will allow 

receiving aircraft to view weather and flight service information. 

The UAT system is specifically designed for ADS-B operation. 

UAT is also the first link to be certified for "radar-like" ATC 

services in the United States. UAT is the only ADS-B link standard 

that is truly bidirectional: UAT users have access to ground-based 

aeronautical data (FIS-B) and can receive reports from proximate 

traffic (TIS-B). UAT equipped aircraft can also observe each other 

directly with high accuracy and minimal latency. 

4.3.4.7.4. ADS-B Transponders– ADS-B-equipped aircraft exchange 

information on one of two frequencies: 1090 or 978 MHz. ADS-B 

extends the message elements of Mode S with additional 

information about the aircraft and its position. This is known as the 

extended squitter and is referred to as 1090ES. 

ADS-B enhances air traffic controllers’ ability to identify and guide 

aircraft. It can also provide coverage in areas where radar is not 

possible, like the Gulf of Mexico or remote regions of Alaska. 

ADS-B enables properly equipped aircraft to broadcast their 

identification, position, altitude, and velocity to other aircraft and to 

ATC. By 2020, all aircraft operating within designated ADS-B 

airspace will be required to comply with the equipment 

performance requirements of ADS-B Out. 

4.3.4.7.5. EMI Failure Modes – Because of the type of signal transmitted by 

the transponders, the applicable failure modes are denial of 

service and degradation of service. Misleading is not considered 

as a viable failure mode. The antennas for redundant systems 

(when installed) may be located in close proximity. Depending on 

antenna placement, common mode failures for this system are 

possible. 

Denial of service is similar to an inoperative transponder system. 

The interfering PED(s) would prevent the aircraft system from 

receiving the desired signal. The aircraft system would indicate or 

“flag” this failure. 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-21 

Degradation of service is very similar denial of service. The 

transponder system may or may not indicate a failure flag, The 

PED interference may cause individual data dropouts caused by 

disruption to the received pulse signals. 

Misleading information is not considered a viable failure mode. 

The information used by transponder systems consist of digital 

framing pulses. Each reply to a transponder consisted of a 

framing pulse, some combination of the possible data pulses, and 

another framing pulse. The typical pulse transmit duration is 

approximately 20ms. In order for a PED EMI to cause misleading 

information, it would have to introduce a random combination of 

pulses, synchronized in time with the receipt of the interrogation 

reply, that is formatted with the exact pulse amplitude and duration 

that correlates with the transponder desired information. The 

probability for this type of failure to occur is so extremely low that 

this failure mode is not considered viable. 

4.3.4.7.6. EMI Failure Effects – The failure effects associated with ILS 

systems are listed in Appendix 2, table reference 4.00. The failure 

condition classification (defined in section 4 of this document) of 

the transponder systems functions are major effects. 

4.3.4.8. Traffic Alert and Collision Avoidance System (TCAS) Interrogator 

Receiver

4.3.4.8.1. TCAS is a system that is designed to alert a flight crew to the 

potential of conflicts with other aircraft within the area. The system 

uses the existing ATCRBS system and the capabilities of Mode S 

transponders to coordinate with other TCAS equipped aircraft. 

TCAS II provides two types of advisories to the flight crew; a traffic 

advisory which informs the flight crew that there are other aircraft 

in the vicinity, and a resolution advisory that advises the flight 

crew a corrective or preventative action is required to avoid an 

intruder aircraft. 

TCAS system processes used to accomplish this function are 

organized into several elements. First, the system surveillance 

sensors collect information about the intruder aircraft (e.g., its 

relative position and velocity) and pass the information to the 

computer to determine whether a collision threat exists. If a threat 

is identified, the system threat-resolution computations determine 

an appropriate response. If the intruder aircraft also has TCAS, 

the response is coordinated through a data link to ensure that 

each aircraft maneuvers in a compatible direction. 

Collision avoidance maneuvers generated and displayed by TCAS 

are treated as advisories to flight crews, who then take manual 

control of the aircraft and maneuver accordingly. Pilots are trained 

to follow TCAS advisories unless doing so would jeopardize 

safety. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-22 

Surveillance of the air traffic environment is based on air-to-air 

interrogations broadcast once per second from antennae on the 

TCAS aircraft using the same frequency (1030 MHz) and 

waveform as ground-based air traffic control sensors. 

Transponders on nearby intruder aircraft receive these 

interrogations and send replies at 1090 MHz. Two types of 

transponders are currently in use: Mode S transponders, which 

have a Mode S address, and older ATCRBS transponders, which 

do not have unique addressing capability. To track ATCRBS 

intruders, TCAS transmits “ATCRBS-only all-call” interrogations 

once per second; all ATCRBS aircraft in a region around the 

TCAS aircraft reply. In contrast, Mode S–equipped intruders are 

tracked with a selective interrogation once per second directed at 

that specific intruder; only that one aircraft replies. 

The antennas used by TCAS include a directional antenna that is 

mounted on the top of the aircraft and either an omnidirectional or 

a directional antenna mounted on the bottom of the aircraft. Most 

installations use the optional directional antenna on the bottom of 

the aircraft. In addition to the two TCAS antennas, two antennas 

are also required for the Mode S transponder. One antenna is 

mounted on the top of the aircraft while the other is mounted on 

the bottom. These antennas enable the Mode S transponder to 

receive interrogations at 1030 MHz and reply to the received 

interrogations at 1090 MHz. 

4.3.4.8.2. EMI Failure Modes – Because of the type of signal transmitted 

and received by the TCAS system, the applicable failure modes 

systems are denial of service and degradation of service. 

Misleading is not considered as a viable failure mode. The TCAS 

uses antennas installed on the top and the bottom of the aircraft 

fuselage. However, since it is a single system, common mode 

failure is not relevant in this case. 

Denial of service is similar to an inoperative TCAS system. The 

interfering PED(s) would prevent the aircraft system from 

receiving the desired signal and associated messages. The 

aircraft system would indicate or “flag” this failure. 

Degradation of service is very similar denial of service. The TCAS 

system may or may not indicate a failure flag, The PED 

interference may cause individual data dropouts caused by 

disruption to the received pulse signals. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-23 

Misleading information in not considered a viable failure mode48. 

The information used by TCAS systems consist of digital framing 

pulses. Each reply to a TCAS interrogation consisted of a framing 

pulse, some combination of the possible data pulses, and another 

framing pulse. In order for a PED EMI to cause misleading 

information, it would have to introduce a random combination of 

pulses, synchronized in time with the receipt of the interrogation 

reply. Each pulse has very tight specifications for position, width, 

and rise and fall times. The transponder signal is complex and is 

difficult to create accidentally. The probability for this type of 

failure to occur is so extremely low that this failure mode is not 

considered viable. 

4.3.4.8.3. EMI Failure Effects – The failure effects associated with TCAS 

systems are listed in Appendix 2, table reference 5.00. The failure 

condition classification (defined in section 4 of this document) of 

the transponder systems functions are major effects. 

4.3.4.9. Global Positioning System (GPS)/Global Navigation Satellite System 

(GNSS)

4.3.4.9.1. GPS (GNSS) Provides accurate, worldwide navigation capability 

with a high degree of availability. GPS navigation information is 

used to supply the aircraft three-dimensional position, velocity, 

track data, time, and other information to other aircraft subsystems 

for use in that system’s navigation, guidance or performance 

computations. GPS systems used for precision navigational 

operations, such as approach and landing have been developed 

to take into account GPS system outages. 

GPS signal data is modulated onto several carrier frequencies. 

Broadcast in the 1559-1610 MHz frequency range is called L1. 

Broadcast the 1164-1215 frequency band is called L5 (or E5) is an 

aeronautical navigation band. 

The signal data is a binary-coded message that contains basically 

three parts. The first part contains the GPS date and time, plus 

the satellite's status and an indication of its health. The second 

part contains orbital information called ephemeris data and allows 

the receiver to calculate the position of the satellite. The third part, 

called the almanac, contains information and status concerning all 

the satellites; their locations and PRN numbers. 

GPS outages are a normal operating condition and can occur 

anywhere in the NAS due to unintentional interference. The 

aircraft-level effect from losing GPS positioning, velocity, and 

timing is a complex problem that depends on the GPS equipment 

design and the degree of integration with other systems. GPS 

outputs are being integrated into a variety of functions beyond 

                                                            

48 See discussion “False TCAS Advisories and PEDs” at http://asrs.arc.nasa.gov/publications/callback/cb_321.htm
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-24 

traditional navigation data. For example, GPS data is being used 

for Terrain Awareness Warning Systems (TAWS); synthetic vision 

systems; ADS-B; and as sensors in air data attitude heading 

reference system (ADAHRS) inputs to electronic primary flight 

displays. There are a wide range of integrations from legacy 

aircraft with self-contained GPS navigation units and a simple 

autopilot interface to new production aircraft with digital cockpits 

using integrated modular avionics providing the advanced 

functions mentioned above and more (including potential GPS 

time applications). 

Satellite Based Augmentation System (SBAS): This system is 

designed for Category I precision approach. GPS/WAAS and 

European Geostationary Navigation Overlay Service (EGNOS) 

are examples of these systems. 

Ground Based Augmentation System (GBAS): This system uses 

ground-based pseudolite emitting signal having similar 

characteristics of GPS. An example is GPS/Local Area 

Augmentation System (LAAS), designed for Category II/III 

precision approach. 

4.3.4.9.2. EMI Failure Modes – Because of the type of signal transmitted by 

the GPS system, the applicable failure modes systems are denial 

of service and degradation of service. Misleading is not 

considered as a viable failure mode. The antennas for redundant 

systems (when installed) may be located in close proximity. 

Depending on antenna placement, common mode failures for this 

system are possible. 

Denial of service is similar to GPS system outage. The interfering 

PED(s) would prevent the aircraft system from receiving the 

desired signal. This would result from an increase in the carrier to 

noise ratio (CNR) at the aircraft’s system antenna. The aircraft 

system would indicate or “flag” this failure. For GPS, the type and 

extent of aircraft system status varies depending on the 

navigational performance level the system was designed to 

provide. GPS system user interfaces (displays or control input 

devices) simply provided “No Computed Data”, or “System Fail” 

warnings. Some systems indicate the number of satellites 

tracked. GPS systems designed for precision navigation include 

indication of GPS signal availability and accuracy information. 

Specific system documentation provides information about how 

GPS data is used by the aircraft systems and how to determine 

degradation of GPS signal reception. 

Degradation of service is similar to denial of service. The GPS 

system may or may not indicate a failure flag, by raising the CNR, 

reception of individual satellites may prohibited. As the number of 

received satellites decreases, GPS system performance is 

affected. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-25 

Misleading information in not considered a viable failure mode. In 

order for a PED EMI to cause misleading information, it would 

have to introduce an error on the binary-coded messages from all 

of the received satellites. The probability for this type of failure to 

randomly occurring is so extremely low that this failure mode is 

not considered viable. 

4.3.4.9.3. EMI Failure Effects – The failure effects associated with GPS 

systems are listed in Appendix 2, table reference 7.00. The failure 

condition classification (defined in section 4 of this document) of 

the GPS systems functions are major effects. 

4.3.4.10. AMS(R)S SATCOM 

SATCOM is a long range radio communication system that provides both 

voice and data communication capabilities. These systems are primarily 

used when the aircraft is out of range of VHF communication system. 

The phase of flight that these systems are used is during cruise. Since 

the cruise phase of flight PED usage allowance is a long time accepted 

practice, no additional analysis of SATCOM was accomplished in the 

report. If an operator uses SATCOM during other phases of flight, the 

system criticality must be evaluated to determine if expanded PED use 

during that flight phase maintains an acceptable level of risk for that 

operation. 

4.3.4.11. Radio Altimeter and Weather Radar - The 4 GHz radio altimeter, the 5 

GHz weather radar, and the 9 GHz weather radar systems have been 

determined in RTCA DO-294 and DO-307 to have sufficient protection 

from PED emissions to not require further analysis. Each of these 

systems use a very directional antenna, limiting the coupling between the 

PED emission and the receiver. Furthermore, PED-induced increases in 

the receiver noise floor only affect receiver outputs at the far limits of 

coverage where the impact of such effects has minimal operational 

impact. Critical operation of such systems, e.g., wind shear detection or 

decision height determination only occur at close ranges where the 

received signal level is sufficient to overcome PED-induced increases in 

the noise floor. 

4.3.4.12. Microwave Landing System (MLS) – At the time of this analysis, there 

were no active MLS systems in the US public airspace system. If an 

operator uses a MLS system as part of their operations, a risk 

assessment similar to this one must be accomplished to determine the 

failure modes PED interference could introduce to the system and 

associated hazards. This must be evaluated before use of PEDs on 

aircraft using MLS systems can be expanded into the approach and 

landing phases of flight. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-26 

5. Risk Analysis

5.1. Failure Condition Classifications.

For the purpose of this assessment, the failure condition classification provided by FAA 

Advisory Circular (AC) 23.1309-1E49 is used. To meet the objectives of this document, 

a failure condition is defined as a condition that can have an effect on either the airplane 

or its occupants, or both, either direct or consequential, which is caused (or attributed 

to) by the associated PED interference failure mode. Failure conditions are classified 

according to their severity as follows: 

5.1.1. No safety effect. Failure conditions that would have no effect on safety (that is 

failure conditions that would not affect the operational capability of the airplane or 

increase crew workload). 

5.1.2. Minor. Failure conditions that would not significantly reduce airplane safety and 

involve crew actions that is within their capabilities. Minor failure conditions may 

include a slight reduction in safety margins or functional capabilities, a slight 

increase in crew workload (such as routine flight plan changes), or some physical 

discomfort to passengers or cabin crew. 

5.1.3. Major. Failure conditions that would reduce the capability of the airplane or the 

ability of the crew to cope with adverse operating conditions to the extent that 

there would be a significant reduction in safety margins or functional capabilities. 

In addition, the failure condition has a significant increase in crew workload or in 

conditions impairing crew efficiency; or a discomfort to the flight crew or physical 

distress to passengers or cabin crew, possibly including injuries. 

5.1.4. Hazardous. Failure conditions that would reduce the capability of the airplane or 

the ability of the crew to cope with adverse operating conditions to the extent that 

there would be the following: 

• A large reduction in safety margins or functional capabilities; 

• Physical distress or higher workload such that the flight crew cannot 

be relied upon to perform their tasks accurately or completely; or 

• Serious or fatal injury to an occupant other than the flight crew. 

5.1.5. Catastrophic. Failure conditions that are expected to result in multiple fatalities of 

the occupants, or incapacitation or fatal injury to a flight crewmember normally 

with the loss of the airplane. 

Notes: The phrase “are expected to result” is not intended to require 100 percent 

certainty that the effects will always be catastrophic. Conversely, just 

because the effects of a given failure, or combination of failures, could 

conceivably be catastrophic in extreme circumstances, it is not intended 

to imply that the failure condition will necessarily be considered 

catastrophic. 

 

                                                            

49 This AC was used to expand the failure condition categories to include “hazardous” failures .  FAA Advisory

Circular (AC) 25.1309‐1A ‐ System Design and Analysis may also be used.
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-27 

6. Likelihood Assessment

6.1. Likelihood assessments can be quantitative, qualitative or include portions of both. 

6.1.1. Quantitative Assessment: A quantitative assessment is an analytical process 

that applies mathematical methods to assess system and airplane safety. 

Quantitative assessments are often used in certification of systems to determine 

the acceptable probability for failure. This drives aircraft design and system 

reliability to ensure that the failure rates meet the assessed probability. Aircraft 

systems are designed to be fail-safe and use a combination of methods such as 

design integrity and quality; redundant systems, back-up systems, component 

reliability, service experience and margins of safety to ensure these systems 

meet the necessary criteria.50 For typical aircraft certification quantitative 

assessment, the rate of failure of systems resulting in a catastrophic event must 

be shown to be extremely improbable. This means that the likelihood of 

occurrence must be less than 1 in 1,000,000,000 (10-9) flight hours for the 

particular aircraft model in the phase of flight that the function that the system 

performs is used. Since passenger PED use varies greatly and is not measured 

in any fashion, it makes justification of PED use based on quantifiable 

operational experience very difficult. This is especially true for those phases of 

flight, such as take-off and landing, where operators currently ask passengers to 

turn PEDs off. 

6.1.2. Qualitative assessment: Qualitative assessments are analytical processes that 

assess system and airplane safety in a subjective, non-numerical manner. These 

assessments use processes such as analysis of system failures and the effect 

they have on the system’s function, as well as the expected response. These 

processes depend on the technical data for the system operation and are based 

on engineering experience and operational judgment. 

6.2. In this assessment, the likelihood for interference from PEDs includes both quantitative 

(where possible) and qualitative assessments using a systematic, deductive, high-level 

examination of potential PED introduced failures. This assessment includes a review of 

operational service experience (service difficulty reports, aviation safety reporting 

system data and other operator specific data), evaluation of known PED spurious 

emissions, a review of existing technical studies accomplished in the various RTCA 

PED activities and a review of the current PED industry statistics. 

For the purpose of this assessment, the evaluation of likelihood associated with the 

failure conditions use definitions as follows: 

6.2.1. Probable failure conditions are those failure conditions anticipated to occur one 

or more times during the entire operational life of each airplane. 

6.2.2. Remote failure conditions are those failure conditions that are unlikely to occur to 

each airplane during its total life but that may occur several times when 

considering the total operational life of a number of airplanes of this type. 

                                                            

50FAA Advisory Circular  (AC) 25.1309‐1A ‐ System Design and Analysis  
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-28 

6.2.3. Extremely remote failure conditions are those failure conditions not anticipated to 

occur to each airplane during its total life but which may occur a few times when 

considering the total operational life of all airplanes of this type. 

6.2.4. Extremely improbable failure conditions are those failure conditions so unlikely 

that they are not anticipated to occur during the entire operational life of all 

airplanes of one type. 

7. Risk Acceptance

7.1. In the development of the risk assessment criteria, the acceptability of risk was 

evaluated using the risk matrices of Appendix 1 and 2, and considers three initial 

levels of acceptability. The standard SMS color scheme is included in this document 

in the following manner: Acceptable (green), Acceptable with mitigation (yellow), and 

Unacceptable (red). 

7.1.1. Unacceptable. Where combinations of avionics system failure effect severity and 

likelihood cause risk to fall into the ‘red area’, the risk has been assessed as 

unacceptable. Systems with catastrophic failure effects are considered to have 

an unacceptable level of risk and therefore, a more structured qualitative 

assessment is required using the RTCA DO-307 path loss measurement 

procedure to ensure that the system meets the latest criteria for PED tolerance. 

7.1.2. Acceptable with Mitigation. Where the risk assessment falls into the ‘yellow area’, 

the risk may be accepted under defined conditions of mitigation. An example of 

this scenario would be an assessment of the impact of an inoperative aircraft 

component redundant to other aircraft systems or operational controls that 

constitute a mitigating action that could make an otherwise unacceptable risk 

acceptable, as long as the other systems are available and the defined 

procedure is implemented. These situations also require continued special 

emphasis during the operator’s safety management system continuous 

improvement safety evaluation function (or equivalent). 

7.1.3. Acceptable. Where the assessed risk falls into the ‘green area’, expanded PED 

use is accepted without further analysis. The objective in risk management 

should always be to reduce risk to as low as practicable regardless of whether or 

not the assessment shows that it can be accepted as is. This is a fundamental 

principle of continuous improvement. 

7.2. Residual risk considers the possible controls and mitigations that may be established 

to reduce the initial assessed risk, based on failure effect severity and likelihood, to an 

acceptable level. For this to occur, the operator must determine that the controls and 

mitigations identified are appropriate for their aircraft and operational profile, that the 

risk control and/or mitigation technique has been implemented and has been 

validated to be effective. See also Sections 8 and 9. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-29 

8. Decision Making

8.1. The assumptions and the failure effects for interference established in Section 3, 

Hazard Identification, established the baseline for setting the mitigations and controls 

for each system function. The mitigation and controls that are identified in Appendix 2 

consider the effect of the PED interference on the function of the avionics system(s). 

The recommended controls listed identify operational procedures, operator PED 

allowance policy or aircraft system testing to address the hazard classification of the 

failure effect. 

8.2. The following residual risks are listed in Appendix 2 and are based on the mitigations 

and controls as follows: 

8.2.1. Acceptable – When the hazard level associated with the effect was established 

to be minor, the mitigation necessary to address the failure mode is already 

addressed as part of standard practices or operating procedures. 

8.2.2. Acceptable with mitigation – Depending on the hazard level and the effect, this 

mitigation could be handled as part of standard practices or operating 

procedures; could have requirements for additional aircraft systems to be used 

as a cross check of independent systems; prohibition of PED allowance; or 

collection of data that determines PED use is acceptable. In order to use this 

assessment as basis for allowing expanded PED use, an operator must 

determine that the controls and mitigations identified are appropriate for their 

aircraft and operational profile, that the risk control and/or mitigation technique 

has been implemented and has been validated as specified in Section 9. 

When mitigation involves dependency on other system functions, the operator 

must assess and address any changes required to their minimum equipment list 

(MEL) allowance for that system as well as the non-normal procedures for the 

operations involving those systems. For example, if an operator mitigates the 

impact of misleading information during an ILS coupled approach by cross 

referencing the aircraft position by using the aircraft’s position based on GPS 

position, then GPS function is required for that operation. The operator should 

revise the MEL to reflect the inoperative GPS functions impact on the ability to 

perform that operation. 

8.2.3. Acceptable only with listed mitigations – In instances where the failure mode 

could result in a catastrophic condition, the mitigation and controls listed are the 

only acceptable means to address the failure mode. In order to allow expansion 

of PED use during these operations, the system must be tested to ensure that 

the interference path loss requirements for front door interference given in DO294 or DO-307 have been met. The operator must possess the data to support 

this determination. Until that data is obtained, the operator must prohibit the use 

of PEDs during the listed avionics system function or alternatively, prohibit the 

use of the listed flight operation. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-30 

9. Validation

9.1. A vital part of any safety management system approach is to continuously monitor the 

performance of the changed functions and measure its performance against planned 

goals. When an operator expands of use of PEDs into new phases of flight, they should 

adopt the principles of safety assurance to validate those operations. 

9.2. Three important aspects of safety assurance are safety performance monitoring 

measurement and review; management of change; and continuous improvement of the 

safety system. 

9.2.1. Safety performance monitoring and measurement should be the process by 

which the safety performance is verified in comparison to its safety policies and 

objectives. This process should include: 

9.2.1.1. Safety reporting - Train flight crews to report intermittent or transient 

avionics problems that they notice during these operations. This should 

not focus on the PEDs as a suspected cause, but rather reporting all 

anomalies. 

9.2.1.2. Safety reviews including trending of data – Operators should incorporate 

reviews of problem and trends as part of their reliability process. 

9.2.1.3. Safety audits – Operators should conduct safety audits of their operations 

to ensure crew compliance with company procedures. This should 

include evaluation of the level of competency and training of their crews. 

9.2.2. Management of change should be a formal process that identifies how expansion 

of use of PEDs may affect their established processes and procedures. The 

affect, and the process or procedures used to address that affect should be 

documented. 

9.2.3. Continuous improvement of the safety system should rectify situations identified 

through safety assurance activities, paying particular attention to critical systems. 

The operator should assess any problems with expected performance and their 

implications in operational safety. Take necessary actions to address these 

problems. 

Note: If a problem is identified that has been confirmed to be 

caused by PED use, that information should be shared 

with the aviation industry via one of the available reporting 

mechanisms. Provide as much detail as possible on how 

the interference was attributed to PED operation and 

include details such as type of device and location in the 

aircraft where device was operated. 

 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-31 

10. Conclusion

10.1. This assessment concluded that the two types of PED interference coupling mechanisms 

can be addressed to provide an acceptable level of safety for expanded PED use. For 

back-door interference (as discussed in section 3.2), system protection is provided in 

several ways including meeting certain HIRF and wireless system installation design 

requirements. For front door interference (as discussed in section 3.3), there are several 

mitigations available. 

10.1.1. PED Tolerance – The best mitigation for front door interference is to obtain data to 

show the system meets the interference path loss requirements for interference as 

shown in DO-294 or DO-307 have been met. This is a requirement for systems that 

have a catastrophic failure condition. 

10.1.2. Operational Mitigations – For systems that have major or minor failure conditions, the 

mitigations are handled as part of standard practices or operating procedures. 

Hazardous effects require additional aircraft systems to be used as a cross check of 

independent systems. This may involve additional crew training to heighten the 

awareness of these requirements. 

10.1.3. Operational Limitations – If an operator opts not perform a function described in the 

safety assessment, then that function does not have to be considered as part of their 

safety assessment. However, if the operation such as CAT II or CAT III was 

previously approved, the operator must surrender that FAA operational authorization 

(operations specification) when applying this operational limitation as a mitigation. 

10.1.4. PED use prohibition – If an operator chooses to use this mitigation, they must assess 

their current PED crew and passenger instructions and make necessary changes to 

convey the appropriate information. There is a hypothesis that once passengers are 

allowed to use PEDs in various phases of flight, they will be hesitant to follow crew 

instruction to shut off the devices when asked. The operator will need to reinforce 

the importance of passenger cooperation should the crew request that devices be 

turned off. This could be either during a phase of flight that passenger PED use is 

not allowed by the operator or in an instance when the crew has detected an 

anomaly which they believe is caused by a PED. In either case, it is a regulatory 

requirement51 that the passengers will follow crew instructions. Therefore it is 

imperative that the instructions provided by the crew are clear and understandable to 

the passengers and convey the appropriate information to allow them to understand 

the reason for the requirement. 

10.2. This assessment reviewed the avionics systems certification hazard classification and 

functions that were available and prevalent at the time of the review. The assessment 

provides an example methodology that can be replicated to assess the impact of PED 

use on other avionics functions as they are adopted, or as changes to the systems 

performing the functions occur. 

10.3. To address this problem in the future, all new avionics systems that perform ‘major’ and 

above functions should be assessed during certification to ensure that they address the 

PED interference environment and adopt PED tolerant design criteria 

 

                                                            

51 See Title 49 – Transportation. Subtitle VII ‐ Aviation Programs PART A – Air Commerce and Safety, Subpart  iv ‐ 

Enforcement and Penalties  
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment Page F-32 

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

Appendix 1 – Predicted Residual Risk – Transmitting PED “Back Door” Interference The risk analysis provides information about the protections provided by HIRF requirements and the residual risk factors for back‐d

described in paragraph 4.2:

Predicted Residual Risk ‐ Transmitting PED “Back Door” Interference

Aircraft That Meet No HIRFRegulations

Aircraft That Meet FAA SpecialConditions

Aircraft That Meet FAA or EASA HIRFRegulations

Aircraft ThSection 3

CATASTROPHIC FAILURE CONDITIONS CATASTROPHIC FAILURE CONDITIONS CATASTROPHIC FAILURE CONDITIONS CATASTROHAZARDOUS FAILURE CONDITIONS HAZARDOUS FAILURE CONDITIONS HAZARDOUS FAILURE CONDITIONS HAZARDOUMAJOR FAILURE CONDITIONS MAJOR FAILURE CONDITIONS MAJOR FAILURE CONDITIONS MAJOR FAIAircraft certified prior to 1987 do not

have verified RF immunity.

Aircraft certified by FAA but not by

JAA/EASA.

Aircraft certified after 1987 by

JAA/EASA or after 2007 by FAA.

Aircraft tha

RTCA/DO‐3

Example: Boeing/McDonnell‐

Douglas/Douglas DC‐9/MD‐80 series

airplanes.This fleet was initially certified before

there were any HIRF special conditions

or regulations.

Example: Boeing 737‐600/700/800/900 series airplanes.

Many systems meet HIRF special

conditions, but some systems retained

from the earlier Boeing 737 models do

not meet FAA and JAA/EASA HIRF

special conditions

DC‐9/MD‐80 US Flight hours from 1995

to 2002: 21,645,272

737‐600/700/800/900 US Flight hours

from 2001 to 2010: 21,370,664

Airworthiness Directives related to RF

interference: None

Airworthiness Directives related to RF

interference: None

Airworthiness Directives related to RF

interference: None

Airworthin

interferenc

US Accident, SDR or NASA ASRS

reports:Catastrophic: NoneHazardous: NoneMajor: 32 ASRS reports 1995 – 2002

US Accident, SDR or NASA ASRS

reports:Catastrophic: None

Hazardous: NoneMajor: 8 ASRS reports 2001 – 2010

US Accident, SDR or NASA ASRS

reports:Catastrophic: None

Hazardous: NoneMajor: None

US Acciden

CatastrophHazardousMajor: Non

(continued)
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

Residual Risk – Catastrophic: Low, withsome uncertaintyNo catastrophic events linked to PEDs.Therefore rate is less than1/21,645,272 or 5x10‐8 per flight hour.This condition has low residual risk, butis not specifically quantified, and hassome uncertainty because the fleethours are less than 1x109.

Residual Risk – Catastrophic: LowNo catastrophic events linked to PEDs.All systems with catastrophic failureconditions meet RF immunity levelssignificantly higher than expectedtransmitting PED RF field strengths.

Residual Risk – Catastrophic: LowNo catastrophic events linked to PEDs.All systems with catastrophic failureconditions meet RF immunity levelssignificantly higher than expectedtransmitting PED RF field strengths.

Residual RNo catastroAll systems conditions significantltransmittin

Residual Risk – Hazardous: LowNo hazardous events links to PEDs.Therefore rate is less than1/21,645,272 or 5x10‐8 per flight hour.Events with Hazardous consequencesshould be extremely remoteoccurrences, or less than once in10,00,000 flight hours (1x10‐7 per flighthour). Therefore this condition has lowresidual risk.

Residual Risk – Hazardous: Low

No hazardous events links to PEDs.

Therefore rate is less than1/21,370,664 or 5x10‐8 per flight hour.Events with Hazardous consequencesshould be extremely remoteoccurrences, or less than once in10,00,000 flight hours (1x10‐7 per flighthour). Therefore this condition has lowresidual risk.

Residual Risk – Hazardous: LowNo hazardous events linked to PEDs.All systems with hazardous failureconditions meet RF immunity levelssignificantly higher than expectedtransmitting PED RF field strengths.

Residual RNo hazardosystems wiconditions higher than RF field str

Residual Risk – Major: Low32 ASRS reports from 1995 to 2002.32/21,645,272 or 1.5x10‐6 per flighthour. Events with Major consequencesshould be remote occurrences, or lessthan once in 100,000 flight hours (1x10‐5

per flight hour). Therefore this

condition has low residual risk.

Residual Risk – Major: Low8 ASRS reports from 2001 to 2010.8/21,370,664 or 4x10‐7 per flight hour.Events with Major consequencesshould be remote occurrences, or lessthan once in 100,000 flight hours (1x10‐5

per flight hour). Therefore this

condition has low residual risk.

Residual Risk – Major: LowNo major events linked to PEDs. Allsystems with major failure conditionsmeet RF immunity levels higher thanexpected transmitting PED RF fieldstrengths.

Residual RNo major esystems wimeet RF imexpected tstrengths.

(continued)
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

1 Hazard ID Transmitting PED Interference2 Hazard Description Transmitting Portable Electronic Devices (PEDs) such as cell phones interfere with an aircraft system with potential cat

failure conditions.

3 Causes The radio frequency power transmitted by the PED, such as a cell phone, couples to wiring or into enclosure for electri

are part of a system whose failure leads to catastrophic, hazardous, or major consequences.

4 System State The aircraft electrical or electronic system performs a function that has potential failures that could lead to catastroph

consequences

5 Existing Controls Existing high intensity radiated fields (HIRF) regulations and associated special conditions require that aircraft electrica

performs functions that have potential failures that could lead to catastrophic consequences must be protected agains

fields. The RF field strengths in the HIRF requirements are significantly higher than the field strengths associated with 

and electronic systems that perform functions with failures that could lead to catastrophic consequences must also me

integrity and availability (such as 14 CFR 25.1309). The physical separation tends to limit common effects to redundan

such as cell phones. Most air carriers prohibit use of transmitting PEDs during aircraft operations, except taxi‐in.

6 Existing Control

Justification/Supporting Data

14 CFR sections 23.1308, 25.1317, 27.1317, and 29.1317. Multiple special conditions such as 25‐302‐SC have been issu

electrical and electronic system installations with failures that could lead to catastrophic effects. Aircraft certified prio

of electrical and electronic systems that have catastrophic failure conditions. 14 CFR 91.21, 121.306, etc. prohibit use 

operator has determined that their use is acceptable.

Multiple aircraft tests have been performed on existing aircraft models to determine if there are adverse effects due t

as cell phones and WiFi devices, with very few effects noted, and those have not been proven to contribute to catastro

7 Effects Potential catastrophic failures could lead to loss of the aircraft and fatalities. Potential hazardous or major failures cou

injuries; fatal injury to a relatively small number of persons (one or two); or a hull loss without fatalities.

8 Severity Catastrophic, hazardous, or major9 Severity Rationale The aircraft safety assessment process categorizes the functions performed by systems and the potential failures assoc

functions. There may be systems with functions whose failure or malfunction could lead to catastrophic, hazardous, o

10 Likelihood Extremely improbable11 Likelihood/ Rationale The RF immunity requirements associated with the HIRF regulations are higher than the RF field strength that transmit

unlikely that these will generate effects that result in catastrophic effects. Aircraft certified prior to 1987 have limited 

with catastrophic failure conditions, are operated daily with exposure to high RF fields in the airport area, and have no

due to these RF fields.

12 Initial Risk Low13 Safety Requirements The existing HIRF regulations and associated special conditions require that aircraft electrical or electronic system that 

potential failures that could lead to catastrophic consequences must be protected against adverse effects due to RF fie

14 FAA Organization

Responsible

AIR‐100/AFS‐360
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

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A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

Appendix 2 – Systems Hazard Assessment by Phase of Operations AFS‐360: PED ARC Avionics System Functional Hazard Risk Assessment, Revision – Original – September 16, 2013

Note: Appendix2 has been formatted for electronic viewing and may also be printed on 11" x 17" paper.

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (Localizer and Glideslope) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

1.01 Loss of ILS function during non‐precision

approach. Not coupled to autopilot and

flight director flags appear.

XS/DS This could cause the crew to transition a visual

approach or execute a missed approach procedure.

This would result in a slight increase in crew

workload as they plan for an alternate approach

procedure.

MIN 6, 7 No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

1.02 Loss of ILS function during non‐precision

approach. Coupled to autopilot. Flight

director flags appear and autopilot

disengages.

XS/DS The crew would take manual control of the aircraft

and transition to a visual approach or execute a

missed approach procedure. This would result in a

slight increase in crew workload as they plan for

an alternate approach procedure

MIN 6, 7 No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

1.03 Misleading information during non‐

precision approach. Not coupled to

autopilot.

ML This could cause the crew to transition to visual a

approach or execute a missed approach

procedure. This would result in a slight increase in

crew workload as they plan for an alternate

approach procedure

MIN 6, 7 No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

1.04 Misleading information during non‐

precision approach. Coupled to autopilot.

ML The crew would take manual control of the aircraft

and transition to a visual approach or execute a

routine missed approach procedure. This wouldresult in a slight increase in crew workload as they

plan for an alternate approach procedure

MIN 6, 7 No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

XS = Denial of service

DS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Aircraft system and pilot function, such as:

A. Crew cross checks using the radio altimeter and

altimeter validates that the aircraft height at the final

approach fix is correct.

B. Use of TAWS (EGPWS) based alerting would alert t

pilots to terrain and obstacles (as equipped).

C. Crew cross checks using a FMS and/or GPS display 

the desired track (lateral position) for the aircraft.

Improper function of an ILS system would result in the

aircraft not being on course, and the FMS and/or GPS

display would show the discrepancy.

D. Crew cross checks using VOR radial to cross check

lateral position on approach.

E. Monitoring other information sources, including bu

not limited to, marker beacon, DME, timing from fixes, e

to validate position on approach.

Option 4.

Do not allow CAT I approaches.

1.05 Loss of ILS function during CAT I precision

approach. Not coupled to autopilot and

flight director flags appear.

XS/DS This would cause the crew to execute a routine

missed approach procedure. This would result in

an increase in crew workload.

MAJ 6, 7

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Aircraft system and pilot function, such as:

A. Crew cross checks using the radio altimeter and

altimeter validates that the aircraft height at the final

approach fix is correct.

B. Use of TAWS (EGPWS) based alerting would alert t

pilots to terrain and obstacles (as equipped).

C. Crew cross checks using a FMS and/or GPS display 

the desired track (lateral position) for the aircraft.

Improper function of an ILS system would result in the

aircraft not being on course, and the FMS and/or GPS

display would show the discrepancy.

D. Crew cross checks using VOR radial to cross check

lateral position on approach.

E. Monitoring other information sources, including bu

not limited to, marker beacon, DME, timing from fixes, e

to validate position on approach.

Option 4.Do not allow CAT I approaches.

1.06 Loss of ILS function during CAT I precision

approach. Flight director flags appear and

autopilot disengages.

XS/DS The crew would assume manual control of the

aircraft and execute a routine missed approach

procedure. This would result in an increase in crew

workload.

MAJ 6, 7

XS = Denial of service

DS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Aircraft system and pilot function, such as:

A. Crew cross checks using the radio altimeter and

altimeter validates that the aircraft height at the final

approach fix is correct.

B. Use of TAWS (EGPWS) based alerting would alert t

pilots to terrain and obstacles (as equipped).

C. Crew cross checks using a FMS and/or GPS display 

the desired track (lateral position) for the aircraft.

Improper function of an ILS system would result in the

aircraft not being on course, and the FMS and/or GPS

display would show the discrepancy.

D. Crew cross checks using VOR radial to cross check

lateral position on approach.

E. Monitoring other information sources, including bu

not limited to, marker beacon, DME, timing from fixes, e

to validate position on approach.

Option 4.Do not allow CAT I approaches.

1.07 Misleading information during CAT I

precision approach. Not coupled toautopilot.

ML May result in no action taken by the crew until

visual conditions were obtained. This would

require crew to initiate a go‐around procedure.

This would result in an increase in crew workloadand a reduction in safety margin.

MAJ 6, 7 

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Aircraft system and pilot function, such as:

A. Crew cross checks using the radio altimeter and

altimeter validates that the aircraft height at the final

approach fix is correct.

B. Use of TAWS (EGPWS) based alerting would alert t

pilots to terrain and obstacles (as equipped).

C. Crew cross checks using a FMS and/or GPS display 

the desired track (lateral position) for the aircraft.

Improper function of an ILS system would result in the

aircraft not being on course, and the FMS and/or GPS

display would show the discrepancy.

D. Crew cross checks using VOR radial to cross check

lateral position on approach.

E. Monitoring other information sources, including bu

not limited to, marker beacon, DME, timing from fixes, e

to validate position on approach.

Option 4.Do not allow CAT I approaches.

1.08 Misleading information during CAT I

precision approach. Coupled to autopilot.

ML May result in no action taken by the crew until

visual conditions were obtained. The crew would

assume manual control of the aircraft and initiate

a go‐around procedure (or initiate an auto‐pilot

TO/GA). This would result in an increase in crew

workload and a reduction in safety margin.

HAZ 6, 7

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Do not allow CAT II/III approaches.

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Do not allow CAT II/III approaches.

Loss of ILS function during CAT II/III

precision approach. Not coupled to

autopilot and flight director flags appear.

XS/DS This would cause the crew to execute go‐around

procedure. This would result in an significant

increase in crew workload and decrease in safety

margin.

MAJ 6, 7

1.10 Loss of ILS function during CAT II/III

precision approach. Flight director flags

appear and autopilot disengages.

XS/DS The crew would assume manual control of the

aircraft and execute a go‐around procedure. Thiswould result in an significant increase in crew

workload and decrease in safety margin.

MAJ 6, 7 

1.09

XS = Denial of service

DS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

1.00 ILS (continued) 4.3.4.3 4.3.4.3.3 4.3.4.3.4

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Do not allow CAT II/III approaches.

Option 1.Front door path loss must be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

Option 2.Do not allow the use of PEDs during these approaches.

Option 3.Do not allow CAT II/III approaches.

6, 7 

1.12 Misleading information during

CAT II/III precision approach. Coupled to

autopilot.

ML May result in no action taken by the crew until

visual conditions were obtained. The crew could

emergency disconnect the autopilot, assume

manual control of the aircraft (or initiate an auto‐

pilot TO/GA) and may not provide the crew

sufficient time to initiate a go‐around or cause the

aircraft to blunder in its approach. This would

result in an significant increase in crew workloadand decrease in safety margin. This would result in

an significant increase in crew workload and

significant decrease in safety margin.

CAT 6, 7 

1.11 Misleading information during CAT II/III

precision approach. Not coupled toautopilot.

ML May result in no action taken by the crew until

visual conditions were obtained. This may not

provide the crew sufficient time to initiate a go‐

around or cause the aircraft to blunder in its

approach. This would result in an significant

increase in crew workload and significantdecrease in safety margin.

CAT

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

2.00 VOR 4.3.4.4. 4.3.4.4.2 4.3.4.4.3.

2.01 Loss of all VOR radio navigation

information accompanied by VOR

indication.

XS/DS During non‐precision VOR approach, the crew

would respond to this by executing a routine

missed approach procedure. This would result in a

slight increase in crew workload as they plan for

an alternate approach procedure.

MIN 3, 4, 6,

7

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

HAZ 3, 4, 6,

7

Option 1‐  Hazardous system classification is only applicable to

aircraft that use VOR as primary navigation source and

possess no other navigation reference.

‐  Front door path loss may be assessed to ensure the

system meets requirements of DO‐294/DO‐307 for the L

and GS systems.

MIN 3, 4, 6,

7

Option 2.For aircraft equipped with other navigational references,

the hazard is minor.

3.00 VHF Voice Comm, VDL Modes 2&3 4.3.4.5. 4.3.4.5.2 4.3.4.5.3.

3.01 XS/DS‐ Loss of primary communications

radio, with secondary VHF COM functioning

properly

XS/DS Communications must be transferred through an

alternate radio that uses a different antennalocation. The crew workload may slightly increase

until the problem is solved.

MIN 2, 3, 4,

6, 7, 8

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

3.02 Loss of all primary communications radios XS/DS When the flight crew realizes communication has

been lost, the appropriate procedure will be

followed to a safe landing. This would result in a

significant increase in workload to the crew.

MAJ 2, 3, 4,

6, 7, 8

Pilot will follow appropriate procedures. No additional

mitigation required due effect of failure.

3.03 Loss of data linked communications XS/DS Crew obtains data via voice or other comm

methods. Slight increase in crew workload.

MIN 2, 3, 4,

6, 7, 8

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

3.04 Loss of Controller‐Pilot Data Link

Communications (CPDLC)

XS/DS Loss of CPDLC capability would result in use of

contingency procedures established in the

applicable geographic region. Slight increase in

flight crew workload due to reversion to voice

communication.

MIN 2, 3, 4,

6, 7, 8

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

2.02 Display of hazardously misleading VOR

radio navigation information to both pilots.

ML During non‐precision VOR approach, crew could

unknowingly lose accurate information relevant to

the aircraft’s location and flight path. This could

result in disorientation near the ground and cause

a considerable workload increase for the crew.

XS = Denial of service

DS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

4.00 ATC SSR Xpndr, Mode S, UAT and ADS‐B

4.3.4.7 4.3.4.7.5 4.3.4.7.6

4.01 Intermittent loss of transponder DS Intermittent loss of transponder function would

result in lapse of altitude information, aircraft

position/track, aircraft identification informationand other required information vital to air traffic

controllers. Often, the transponder is integrated

with ADS‐B and that functionality would also be

intermittently lost. Intermittent reporting ofaircraft position information, if lapse exceeds

limits of air traffic automation, could require

communication with ATC to re‐establish

identification. Intermittent TCAS "off" indicationscould also occur. Crew and ATC workload wouldincrease.

MIN 2, 3, 4,

6, 7

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

4.02 Complete loss of transponders XS Loss of all transponder function would result in

loss of altitude information, aircraft position/track,

aircraft identification information and other

required information vital to air traffic controllers.

Often, the transponder is integrated with ADS‐B

and that functionality would also be lost. Aircraft

position information would be lost to other aircraft

in the vicinity using TCAS and Traffic Information

Services‐Broadcast (TIS‐B). With loss of ADS‐B, theflight crew would have to avoid Class A, class B,

and class C airspace, or require special handling

from ATC. Significant increase in crew workload

and decrease in safety margins.

MAJ 2, 3, 4,

6, 7

Pilot will follow appropriate procedures. No additional

mitigation required due effect of failure.

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(continued)

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

5.00 TCAS 4.3.4.8 4.3.4.8.2 4.3.4.8.35.01 Loss of TCAS when in an advisory situation XS/DS TCAS does not alter or diminish the pilot’s basic

authority and responsibility to ensure safe flight.

Since TCAS does not respond to aircraft which are

not transponder equipped or aircraft with a

transponder failure, TCAS alone does not ensure

safe separation in every case. Loss of TCAS

functionality will result in a slight decrease in

safety margins. The crew must rely on visual

separation if operating under VFR conditions orATC provided separation if operating IFR under

IMC conditions.

MIN 3, 4, 6,

7

No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

6.00 DME 4.3.4.6 4.3.4.6.2 4.3.4.6.36.01 Loss of DME information during approach.

No data or erratic data displayed.

XS/DS DME issued to provide distance to touchdown for

ILS approaches. When specified in an the approach

procedure, DME is used in lieu of the outer marker,

can be used as a back course final approach fix,

and is used to establish other fixes on the localizer

course. This would result in a slight increase in

crew workload.

MIN 6, 7 No additional mitigation required due to classification o

failure. Pilot will follow appropriate procedures.

XS = Denial of serviceDS = Degradation of signal

ML = Misleading information
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

Table

Ref. Avionics System Function

Failure

ModeCodes Effect of PED interference on aircraft operation

Hazard Class

(As certificated)

Phase of flight Mitigations 

7.00 GNSS (L1/L5/E5) 4.3.4.9 4.3.4.9.2 4.3.4.9.3

7.01 Loss of all GPS navigation information for

terminal area navigation (includingdepartures) and nonprecision Approach

(e.g. LNAV or RNP <1, RNAV SIDs)

XS/DS Loss of GPS navigation information during this

operating phase could result in flight crewdiscontinuing GPS approach and potentially

required missed approach.

Loss of GPS function during departure would not

significantly impact the RNAV SID operationsbecause the selection of ground based NAV aids,the navigation system accuracy would not degrade

to an unacceptable level within the time frame ofthe departure.The crew may resort to other navigational systems

if available. This would result in a reduction insafety margin, and a increase in crew workload.

MAJ 2, 3, 4,

6, 7

Pilot will follow appropriate procedures. No additional

mitigation required due effect of failure.

7.02 Loss of all GPS navigation information

during nonprecision approach with Vertical

Guidance (LNAV/VNAV)

XS/DS Loss of GPS navigation information during this

operating phase occurs prior to the final approach

waypoint (FAWP), the approach should not be

completed since GPS may no longer provide the

required accuracy. The crew may resort to other

navigational systems if available. This would

result in a significant reduction in safety margin,

and a significant increase in crew workload.

MAJ 6, 7 Pilot will follow appropriate procedures. No additional

mitigation required due effect of failure.

7.03 Loss of all GPS navigation information

during LP/LPV and GNSS Category I/II

approaches.

XS/DS Loss of GPS navigation information during this

operating phase occurs prior to the final approach

waypoint (FAWP), the approach should not be

completed since GPS may no longer provide the

required accuracy. If the flag/status annunciation

appears after the FAWP, the missed approachshould be executed immediately. This would

result in a significant reduction in safety margin,and a significant increase in crew workload.

MAJ 6, 7 Pilot will follow appropriate procedures. No additional

mitigation required due effect of failure.

XS = Denial of service

DS = Degradation of signalML = Misleading information

1 2 3 4 5 6 7 

Parked Taxi Takeoff &

Departure

takeoff to

transition‐to‐

climb altitude

and/or gear

up

Climb Cruise Descent

to IAF

and/or flaps

Approach

IAF or flaps

to visual

reference to

landing

10’000 AGL 10’000 AGL
A Report from the PED ARC to the FAA

Appendix F: Avionics System Functional Hazard Risk Assessment 

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-1 

APPENDIX G:		 PED STOWAGE POLICY ASSESSMENT & CONSIDERATIONS

Appendix G includes the PED Stowage Policy Assessment and Considerations Report as 

amended by the PED ARC on September 25, 2013. 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-2 

(intentionally left blank)

   
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-3 

\

Portable Electronic Device (PED) Aviation Rulemaking Committee 

PED Stowage Policy Assessment and Considerations 

Summary 

The PED ARC has determined the need for a Portable Electronic Device (PED) 

stowage policy assessment on aircraft used in commercial passenger air 

transportation. The ARC tasked a working group to present considerations to 

assist commercial aircraft operators in developing a PED stowage policy that 

would work in concert with an expanded PED use policy. This paper 

summarizes FAA relevant regulations and guidance, evaluates current industry 

PED policies, and provides considerations to standardize industry best 

practices for stowage of PEDs as appropriate. 

September 25, 2013 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-4 

Portable Electronic Device Aviation Rulemaking Committee 

PED Stowage Policy Assessment and Considerations 

Contents 

1. Background .................................................................................................................................. G-5 

1.1. Purpose ........................................................................................................................................ G-5 

1.2. Applicability & Scope .................................................................................................................... G-5 

1.3. Charter ......................................................................................................................................... G-5 

1.4. Definitions .................................................................................................................................... G-6 

2. Current FAA Regulations and Guidance ...................................................................................... G-7 

2.1. Regulations .................................................................................................................................. G-7 

2.1.1. Portable Electronic Devices(14 CFR § 121.306) ......................................................................... G-7 

2.1.2. Carry-on Baggage (14 CFR § 121.589) ....................................................................................... G-8 

2.1.3. Stowage Compartments (14 CFR § 25.787) ............................................................................... G-9 

2.1.4. Part 25, Subpart C – Structure, General (14 CFR § 25.561) ..................................................... G-10 

2.2. Guidance .................................................................................................................................... G-10 

2.2.1. Carry-On Baggage (AC 121-29B) .............................................................................................. G-10 

2.2.2. Use of Portable Electronic Devices Aboard Aircraft (AC 91-21.1B) .......................................... G-12 

2.2.3. Passenger Safety Information Briefing and Briefing Cards (AC 121-24C) ................................ G-13 

2.2.4. Stowage of Items in Seat Pockets (InFO 09018) ....................................................................... G-15 

2.2.5. Transport Airplane Cabin Interiors Crashworthiness Handbook) .............................................. G-16 

2.2.6. Corded Electrical Devices Used in the Passenger Cabin (ANM–02–115–20) .......................... G-16 

3. Survey of Current Industry Stowage Policies ............................................................................ G-17 

3.1. Background ................................................................................................................................ G-17 

3.2. Survey Questions and Summary of Responses ........................................................................ G-17 

3.3. Discussion of Survey Results .................................................................................................... G-18 

4. PED Stowage Considerations .................................................................................................... G-19 

4.1. Key Issues to Consider .............................................................................................................. G-19 

4.2. Key Questions ............................................................................................................................ G-21 

4.3. Minimize Variability of Stowage Policies .................................................................................... G-23 

4.4. Develop a Public Messaging Strategy ....................................................................................... G-23 

Appendix 1: PED Stowage Survey Responses ...................................................................................... G-25 

Appendix 2: AAM-630 Memorandum, Recommendations for PED Usage Onboard Airliners ............... G-31 

 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-5 

1. Background

1.1. Purpose

The Federal Aviation Administration (FAA) Portable Electronic Devices Aviation 

Rulemaking Committee (PED ARC) is tasked to make suggestions to further clarify 

and provide guidance on allowing additional PED use by passengers in the cabin 

without compromising the continued safe operation of the aircraft. The PED ARC 

stowage policy working group was established to evaluate PED policies in use 

today by Title 14, Code of Federal Regulations (14 CFR) Part 119 certificate 

holders. Since a migration to “PED tolerant” airplanes will allow passengers’ devices 

to remain powered on throughout flight, the team was also asked to consider 

expanding the windows of time that passengers may use their electronic devices, 

without adversely affecting cabin safety. 

1.2. Applicability & Scope

This document, PED Stowage Policy Assessment and Considerations is a product 

of the Portable Electronic Device Aviation Rulemaking Committee based on the 

evaluation conducted by the PED Stowage working group. This report serves as 

suggested guidance for those 14 CFR 119 certificate holders that desire to allow 

passengers to utilize PEDs in any phase of flight on their aircraft. The air carrier is 

ultimately responsible for passenger safety. Procedures may vary due to differences 

in air carrier operations and aircraft. The scope of this document is limited to 

passenger PED stowage as related to carry-on baggage policies. The use of the 

terms “aircraft operator(s)” and “operator” throughout this document is applicable to 

operations conducted under 14 CFR parts 91k, 121, 125 and 135. 

The working group’s efforts included contacting and working with the FAA Office of 

Aerospace Medicine (AAM-600) and Cabin Safety Inspectors (CSI), Airlines for 

America (A4A), the Association of Flight Attendants-CWA (AFA), the National 

Business Aviation Association (NBAA), the National Air Transportation Association 

(NATA), the Association of Professional Flight Attendants (APFA), the Regional 

Airline Association (RAA), and other interested stakeholders. 

1.3. Charter

The PED ARC Stowage Working Group will recommend guidance to enable 

operators to develop a PED stowage policy that would work in concert with an 

expanded PED usage policy. 

   
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-6 

1.4. Definitions

A Portable Electronic Device (PED) is any piece of lightweight, electricallypowered equipment. These devices are typically consumer electronic devices 

functionally capable of communications, data processing and/or utility. 

To stow an item, according to one dictionary definition, is “to put (something that is 

not being used) in a place where it is available, where it can be kept safely, etc.”52

Stowage, therefore, is simply a “space especially on a ship or airplane for stowing 

things.”53 For purposes of this report, a stowage location on an airplane is generally 

one that is approved for stowage by the operator, and placarded with a maximum 

weight restriction. If an item is located in a place that lacks formal operator approval 

or a maximum weight placard, but where it is considered, in the judgment of the 

operator, that in a survivable incident (e.g., severe turbulence during a critical phase 

of flight) the item is unlikely to threaten any occupant’s safety (e.g., restricting 

egress from a seat during an emergency evacuation) or lead to one or more 

injuries, this report refers to that item’s condition as “secure”. Some factors that 

help determine the relative safety of a secure location include the size, shape, and 

weight of the passenger’s item, as well as the holding properties of the location 

itself. 

   

                                                            

52 Hyperlink: Merriam-Webster online dictionary [http://www.merriam-webster.com/dictionary/stow] Accessed September 19, 2013. 53 Hyperlink: Merriam-Webster online dictionary [http://www.merriam-webster.com/dictionary/stowage] Accessed September 19, 

2013.
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-7 

2. Current FAA Regulations and Guidance

The following sections summarize and discuss current FAA regulatory, policy, and guidance 

documents relevant to stowage of passenger items in the cabin. 

2.1. Regulations

Pertinent parts of the applicable regulations have been excerpted here for this 

discussion. Footnotes have been provided to link to the full regulatory language. 

2.1.1.Portable Electronic Devices (14 CFR § 121.306)

Portable electronic devices regulation 121.306 gives operators the authority to 

determine whether particular devices may be used on board their aircraft: 54

§ 121.306 Portable electronic devices. 

(a) Except as provided in paragraph (b) of this section, no person may 

operate, nor may any operator or pilot in command of an aircraft allow 

the operation of, any portable electronic device on any U.S.-registered 

civil aircraft operating under this part. 

(b) Paragraph (a) of this section does not apply to— 

(1) Portable voice recorders; 

(2) Hearing aids; 

(3) Heart pacemakers; 

(4) Electric shavers; or 

(5) Any other portable electronic device that the part 119 certificate 

holder has determined will not cause interference with the navigation or 

communication system of the aircraft on which it is to be used. 

(c) The determination required by paragraph (b)(5) of this section shall 

be made by that part 119 certificate holder operating the particular 

device to be used. 

   

                                                            

54 Hyperlink: §121.306 Portable electronic devices [http://www.ecfr.gov]; Accessed September 19, 2013. 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-8 

2.1.2.Carry‐on Baggage (14 CFR § 121.589)

14 CFR § 121.589 paragraphs (b) - (f) specify requirements for ensuring that 

cabin items are properly secured during takeoff and landing operations: 55

§ 121.589 Carry-on baggage. 

* * * * 

(b) No certificate holder may allow all passenger entry doors of an 

airplane to be closed in preparation for taxi or pushback unless at least 

one required crewmember has verified that each article of baggage is 

stowed in accordance with this section and § 121.285 (c) and (d). 

(c) No certificate holder may allow an airplane to take off or land unless 

each article of baggage is stowed: 

(1) In a suitable closet or baggage or cargo stowage compartment 

placarded for its maximum weight and providing proper restraint for all 

baggage or cargo stowed within, and in a manner that does not hinder 

the possible use of any emergency equipment; or 

(2) As provided in § 121.285 (c) and (d); or 

(3) Under a passenger seat. 

(d) Baggage, other than articles of loose clothing, may not be placed in 

an overhead rack unless that rack is equipped with approved restraining 

devices or doors. 

(e) Each passenger must comply with instructions given by 

crewmembers regarding compliance with paragraphs (a), (b), (c), (d), 

and (g) of this section. 

(f) Each passenger seat under which baggage is allowed to be stowed 

shall be fitted with a means to prevent articles of baggage stowed under 

it from sliding forward. In addition, each aisle seat shall be fitted with a 

means to prevent articles of baggage stowed under it from sliding 

sideward into the aisle under crash impacts severe enough to induce the 

ultimate inertia forces specified in the emergency landing condition 

regulations under which the airplane was type certificated. 

* * * * 

   

                                                            

55 Hyperlink: §121.589 Carry-on baggage [http://www.ecfr.gov]; Accessed September 19, 2013. 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-9 

2.1.3.Stowage Compartments (14 CFR § 25.787)

14 CFR § 25.787 paragraphs (a) and (b) specify the design requirements for 

approved stowage compartments: 56

§25.787 Stowage compartments 

(a) Each compartment for the stowage of cargo, baggage, carry-on articles, 

and equipment (such as life rafts), and any other stowage compartment 

must be designed for its placarded maximum weight of contents and for the 

critical load distribution at the appropriate maximum load factors 

corresponding to the specified flight and ground load conditions, and to the 

emergency landing conditions of § 25.561(b), except that the forces 

specified in the emergency landing conditions need not be applied to 

compartments located below, or forward, of all occupants in the airplane. If 

the airplane has a passenger seating configuration, excluding pilots seats, 

of 10 seats or more, each stowage compartment in the passenger cabin, 

except for underseat and overhead compartments for passenger 

convenience, must be completely enclosed. 

(b) There must be a means to prevent the contents in the compartments 

from becoming a hazard by shifting, under the loads specified in paragraph 

(a) of this section. For stowage compartments in the passenger and crew 

cabin, if the means used is a latched door, the design must take into 

consideration the wear and deterioration expected in service. 

* * * * 

 

                                                            

56 Hyperlink: §25.787 Stowage compartments [http://www.ecfr.gov]; Accessed September 19, 2013. 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-10 

2.1.4.Part 25, Subpart C – Structure, General (14 CFR § 25.561)

14 CFR § 25.561 paragraph (b) lists specific inertia forces experienced during 

emergency landing conditions on land or water: 57

§ 25.561 General. 

* * * * 

(b) The structure must be designed to give each occupant every reasonable 

chance of escaping serious injury in a minor crash landing when— 

(1) Proper use is made of seats, belts, and all other safety design 

provisions; 

(2) The wheels are retracted (where applicable); and 

(3) The occupant experiences the following ultimate inertia forces acting 

separately relative to the surrounding structure: 

(i) Upward, 3.0g 

(ii) Forward, 9.0g 

(iii) Sideward, 3.0g on the airframe; and 4.0g on the seats and their 

attachments. 

(iv) Downward, 6.0g 

(v) Rearward, 1.5g 

* * * * 

2.2. Guidance

This section lists several FAA policy and guidance documents that expand on and 

clarify existing regulations and generally provide one means, although not the only 

means, for complying with those regulations. Relevant portions of these documents 

are excerpted in the following sections: 

2.2.1.Carry‐On Baggage (AC 121‐29B)

Advisory Circular (AC) 121-29B “provides information about features that the ... 

FAA ... recommends be included in air carriers’ carry-on baggage programs 

[and] provides clarification to air carriers about how to comply with FAA’s carryon baggage regulations.”58The following portions of the AC address issues 

relevant to stowage of PEDs: 

 

                                                            

57 Hyperlink: §25.561 Structures, General [http://www.ecfr.gov]; Accessed September 19, 2013. 58 Hyperlink: FAA AC 121-29B Carry-On Baggage [http://rgl.faa.gov]; Accessed September 19, 2013. 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-11 

Excerpt - FAA Advisory Circular 121-29B: 

4. What should your FAA-approved carry-on baggage program address? 

... 

d. Explain how you intend to stow carry-on baggage properly. This part of the 

program depends on the type of aircraft covered by the program, including 

cabin configuration and other space factors. Your stowage program should 

ensure that: 

(1) Carry-on baggage does not obstruct passenger movement to, from, or 

across the aisle; 

... 

e. Describe your procedures to verify that each article of baggage is properly 

stowed in an approved compartment or other specifically approved area before 

flight attendants close the passenger entry doors on each flight. The FAA 

recommends that you task a specific crewmember, such as the lead flight 

attendant, with verifying proper stowage. Your description should include: 

(1) Methods to ensure carry-on baggage and cargo do not exceed the FAAapproved weight limitations or load limits for the specific place they are stowed, 

including the restraints used to secure them. ... 

i. Establish procedures for informing travelers and travel agents about the 

specific carry-on requirements of your flights. You may accommodate travelers 

with special baggage problems, provided you can stow the baggage safely. ... 

j. Include information about your carry-on baggage program in the appropriate 

parts of the crewmembers’ manual. You should cover all of the elements listed 

above, especially crewmember responsibility for verifying that baggage is 

stowed properly and will not hinder the availability and use of emergency 

equipment; and other pertinent information that the principal operations 

inspector determines should be in the crewmembers’ manual. 

k. Provide training to appropriate ground personnel and to all crewmembers 

regarding your approved carry-on baggage program. The training should 

include at least carry-on baggage limitations; baggage scanning; processing of 

carry-on baggage that you cannot accommodate in any of the passenger 

compartments; proper stowing of carry-on baggage, cargo and unusual items in 

the cabin; crew coordination; applicable passenger information; types of and 

limitations on stowage provisions; verification that carry-on baggage is stowed 

so it does not interfere with emergency equipment; and how to handle carry-on 

baggage during an emergency. 

   
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-12 

2.2.2. Use of Portable Electronic Devices Aboard Aircraft (AC 91‐21.1B)

Advisory Circular 91-21.1B provides aircraft operators with information and 

guidance that are one means, but not the only means, for complying with 14 CFR 

§ 91.21. 59 

Excerpt - FAA Advisory Circular 91-21.1B: 

6. RECOMMENDED PROCEDURES FOR THE OPERATION OF PEDs 

ABOARD AIRCRAFT. If an operator allows the use of PEDs aboard its aircraft, 

procedures should be established and spelled out clearly to control their use 

during passenger-carrying operations. The procedures, when used in conjunction 

with an operator’s program, should provide the following:

a. Methods to inform passengers of permissible times, conditions, 

and limitations when various PEDs may be used. This may be 

accomplished through the departure briefing, passenger information 

cards, captain’s announcement, and other methods deemed 

appropriate by the operator. For air carrier operations conducted 

under 14 CFR part 121 or part 135, the limitations, as a minimum, 

should state that use of all such devices (except certain inaccessible 

medical electronic devices, for example, heart pacemakers) are 

prohibited during any phase of operation when their use could 

interfere with the communication or navigation equipment on board 

the aircraft or the ability of the flightcrew to give necessary 

instructions in the event of an emergency. 

... 

f. Prohibiting the operation of any PEDs during the takeoff and 

landing phases of flight. It must be recognized that the potential for 

personal injury to passengers is a paramount consideration, as well 

as is the possibility of missing significant safety announcements 

during important phases of flight. This prohibition is in addition to 

lessening the possible interference that may arise during sterile 

cockpit operations (below 10,000 feet). 

   

                                                            

59 Hyperlink: FAA AC 91-21.1B Use of Portable Electronic Devices Aboard Aircraft [http://www.faa.gov]; Accessed September 19, 

2013. 
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2.2.3. Passenger Safety Information Briefing and Briefing Cards (AC 121‐24C)

Advisory Circular 121-24C provides aircraft operators with “information regarding 

the items that are required to be, or should be, covered in oral passenger 

briefings and on passenger briefing cards.” 60 

Excerpt - FAA Advisory Circular 121-24C: 

1. ORAL BRIEFINGS. The pretakeoff oral briefing should be given so 

that each passenger can clearly hear it and easily see required 

demonstrations. ... 

... 

a. Pretakeoff. Before each takeoff, the operator must ensure that all 

passengers are orally briefed on each of the following: 

... 

(9) Portable Electronic Devices. Except as provided in § 91.21, no 

part 119 certificate holder or pilot in command may operate or allow 

the operation of portable electronic devices on any U.S.-registered 

aircraft operated by the certificate holder. Passengers should be 

informed of permissible times, conditions, and limitations when 

various portable electronic devices may be used. 

c. Prelanding. A prelanding briefing is recommended and should 

include the following: seatbelts must be securely fastened; smoking 

materials must be extinguished; tray tables must be secured in their 

stowed position; seat backs must be in a fully upright position; food, 

beverages, or tableware must be picked up; and carry-on baggage 

and movie/video screens must be properly stowed for landing. 

... 

e. Crewmember Procedures. Each oral briefing provided by a carrier 

or commercial operator for its passengers must be explained and 

described in appropriate manuals. The manuals should also contain 

a description of flight attendant tasks and coordination procedures to 

ensure passenger compliance with information signs and flight 

attendants’ safety instructions. This description should include the 

stipulation that flight attendants should notify the pilot in command 

anytime a passenger is not complying with safety instructions. Flight 

attendants should neither be assigned nor perform nonsafety-related 

duties during the safety briefings if those duties could obstruct the 

view of the passengers or distract them from listening. 

   

                                                            

60 Hyperlink: FAA AC 121-24C Passenger Safety Information Briefing and Briefing Cards [http://rgl.faa.gov/]; 

Accessed September 19, 2013. 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-14 

2. PASSENGER SAFETY BRIEFING CARDS. Oral briefings must be 

supplemented with briefing cards, which must be pertinent only to that 

type and model of aircraft and consistent with the airline’s procedures. 

The information on the cards should be consistent with the information 

contained in the air carrier’s manuals. When aircraft equipment is 

substantially different, even within the same model of aircraft, the air 

carrier should provide information cards specific to that aircraft. ... 

... 

c. Content. Safety briefing cards that provide information to 

passengers should include: 

... 

(14) Portable Electronic Devices. The cards should inform 

passengers of permissible times, conditions, and limitations when 

various portable electronic devices may be used. 

(15) Supplemental Information. The cards may contain supplemental 

instructions. For example, for takeoff and landing, carry-on baggage 

and tray tables must be properly stowed, galley service items must 

be collected from passengers and stowed, and seat backs must be 

placed in their fully upright position. 

   
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-15 

2.2.4. Stowage of Items in Seat Pockets (InFO 09018)

Information for Operators (InFO) 09018, Stowage of Items in Seat Pockets, dated 

November 12, 2009, provides clarifying guidance for air carriers about the 

stowage of items in seat pockets.61

The intent of the carry-on baggage regulation, Title 14 of the Code of 

Federal Regulations (14 CFR) part 121, section 121.589, is to prevent 

carry-on items from slowing an emergency evacuation and to prevent 

injury to passengers by ensuring items are properly restrained. Seat 

pockets have been designed to restrain approximately 3 pounds of 

weight and not the weight of additional carry-on items. Seat pockets are 

not listed in the regulation as an approved stowage location for carry-on 

items. If a seat pocket fails to restrain its contents, the contents of the 

seat pocket may impede emergency evacuation or may strike and injure 

a passenger. 

If small, lightweight items, such as eyeglasses or a cell phone can be 

placed in the seat pocket without exceeding the total designed weight 

limitation of the seat pocket or so that the seat pocket does not block 

anyone from evacuating the row of seats; it may be safe to do so. 

The requirements of the carry-on baggage regulation are applicable to 

take-off and landing. Nothing in the carry-on baggage regulation 

prohibits a passenger from taking out small personal items from an 

approved stowage location and placing them in the seat pocket after 

takeoff and stowing them in approved locations prior to landing. 

Crewmembers may still direct a passenger to stow carry-on items in an 

approved stowage location, during flight should they pose a hazard, 

such as in the case of turbulence. 

Existing FAA policy in Order 8900.1, Volume 3, Chapter 33, Section 6, 

Operations—Cabin Safety,62 states that carry-on baggage programs should: 

• Prohibit the stowage of carry-on baggage and other items in the 

lavatories and seat pockets (the only items allowed in seat 

pockets should be magazines and passenger information cards) 

• Provide specific crewmember assignments for the verification that 

carry-on baggage is properly stowed 

• Address procedures in appropriate manuals 

• Provide crewmember training on carry-on baggage, and 

• Ensure that information is available to the public about the air 

carrier’s carry-on baggage program 

   

                                                            

61 Hyperlink: FAA InFO 09018 [http://www.faa.gov] Accessed September 19, 2013. 62 Hyperlink: Order 8900.1, Volume 3, Chapter 33, Section 6, Operations, Cabin Safety [http://fsims.faa.gov] Accessed September 

19, 2013. 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-16 

2.2.5. Transport Airplane Cabin Interiors Crashworthiness Handbook (AC 25‐17A)

Passenger PEDs that are sufficiently thin may slide out from under-seat stowage 

locations into aisles,63 creating tripping hazards and/or obscuring emergency 

path lighting, given the gap allowed beneath under-seat restraints as noted on 

page 156 of AC 25-17A: 64

(G) The bottom of the restraint system should be no more than 2 1/2-

inches above the floor level of the airplane. The top of the system 

should be no less than 3-inches above the floor level of the airplane. 

(Amendment 25-32). 

2.2.6. Corded Electrical Devices Used in the Passenger Cabin (ANM–02–115–20)

FAA Policy Statement No. ANM–02–115–20, dated November 21, 2002, 

consolidates and clarifies “certification policy for addressing potential hazards 

associated with the installation of corded electrical devices used in the passenger 

cabin.” 65 Specific sections of 14 CFR Part 25 design regulations are cited that 

require passageways leading from main aisles to various types of exit doors, 

between individual passenger areas, and cross aisles between main aisles, be 

unobstructed. 

 

                                                            

63 Excerpt and Hyperlink: From FAA Order 8900.1, Volume 3, Chapter 33, Section 6, Operations—Cabin Safety, 3-

3548. STOWAGE OF NON-COLLAPSIBLE FLEXIBLE TRAVEL CANES: “The FAA requires that passenger seats, 

under which baggage is allowed to be stowed, must be equipped with under-seat restraints sufficient to prevent 

articles of baggage, including flexible travel canes and other thin profile items of baggage, from sliding forward.” 

Accessed September 19, 2013. 

64 Hyperlink: FAA AC 25-17A Transport Airplane Cabin Interiors Crashworthiness Handbook [http://www.faa.gov]; 

Accessed September 19, 2013. 

65 Hyperlink: FAA Policy Statement No. ANM–02–115–20 Corded Electrical Devices Used in the Passenger Cabin 

[http://www.airweb.faa.gov]; Accessed September 19, 2013.
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-17 

3. Survey of Current Industry Stowage Policies

3.1. Background

The PED stowage working group developed a survey to request information from various 

aviation industry stakeholders about current operator policies related to stowage of 

PEDs. Surveys were emailed to, and completed by, FAA Certificate Management Office 

(CMO) staff, Part 121 operators, flight attendants, and one aircraft manufacturer. In all, 

41 completed surveys were returned. 

3.2. Survey Questions and Summary of Responses

The table below includes the full text of all survey questions, as well as numbers of 

responses in each category. Respondents were asked to answer Yes or No to each 

question, and to leave items blank if unsure. However, many of the participants did not 

always follow this guidance. For purposes of the summary table, in most cases, alternate 

responses were converted to Yes, No, or blank following inspection, although a small 

number were categorized as “OTHER” when the other three options could not be 

applied. Detailed results are provided in Appendix 1. 

# Question Response

Yes No Blank Other

1 Does your aircraft operation have a policy requiring stowage of some or all passenger PEDs

at any point during a flight? If Yes, please answer questions 1a‐h, and attach text of policy,

if possible.

38 3 0 0

1a Doesthe policy require stowage of passenger PEDs undersome flight conditions and/or phases of 36 4 1 0

1b Does the policy treat different sizes and/or weights of passenger PEDs differently? 21 17 2 1

1c Does the policy allow passenger PEDs to be stowed in seat pockets? 25 15 1 0

1d Does the policy limit the weight of items, including passenger PEDs, stowed in seat 28 6 6 1

1e Does the policy limit seat pocket stowage to ensure that passengers can egress safely

during an emergency?

34 4 3 0

1f Does the policy specifically restrict the use/stowage of wired headsets? 7 30 3 1

1g Does the policy specifically restrict the use/stowage of wireless headsets? 10 25 5 1

1h Does your aircraft operation have crewmember reports of incidents involving passenger

Non‐compliance with PED stowage requirements? If Yes, please attach examples, if

19 7 15 0

2 Do any of your aircraft have seat power plugs installed for passenger use? If Yes, please

answer questions 2a‐b.

15 24 2 0

2a Can passenger PEDs be connected to seat power during all phases of flight? 4 12 25 0

2b Can cabin crewmembers disable seat power? If Yes, please answer questions 2c‐d. 11 4 25 1

2c At individual seats? 2 12 26 1

2d In separate sections of the airplane? 8 6 26 1

3 Are crewmembers (pilots and/or flight attendants) required to make announcement(s) to

passengers related to stowage of PEDs? If Yes, please attach text of announcement(s), if

possible.

33 8 0 0

4 Does your aircraft operation require crewmembers (pilots and/or flight attendants) follow

specific procedures to enforce its passenger PED stowage policies? If Yes, please attach

details, if possible.

25 13 3 0

5 Does your aircraft operation have reports of passenger PEDs thrown about the cabin due to

turbulence, hard landing, or sudden stop acceleration/deceleration? If Yes, please attach

redacted copies or summaries of incident reports, if possible.

1 26 14 0
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-18 

3.3. Discussion of Survey Results

The stowage policies survey results tabulated above provide responses of operator 

policies across domestic passenger air transport operations. Participants were drawn 

from FAA Certificate Management Office personnel, Part 121 operators both directly 

and anonymously through the trade association Airlines for America (A4A), 

Association of Flight Attendants-CWA (AFA) safety committee chairpersons, one 

other air carrier union, and one aircraft manufacturer. 

Some general perspectives on current stowage policies and practices may be 

observed. First, it is clear from responses to questions 1 and 1a, in which 93% and 

88% of all participants, respectively, answered yes, that most operators appear to 

require that passenger PEDs be stowed at some point during a flight, which 

conforms to the guidance in InFO 09018. The responses to 1b suggest that only 

about half of operators (51% Yes) have policies that distinguish between different 

sizes/weights of PEDs. The responses to 1c and 1d suggest that about two-thirds of 

operators allow the use of seat pockets as stowage for PEDs and/or restrict the 

weight of items stowed in seat pockets (61% and 68% Yes, respectively). The 

responses to 1e suggest that most operators (83% Yes) consider safe egress during 

an emergency in their seat pocket stowage policies, although the responses to 1f 

suggest that most do not consider wireless headsets to be an egress issue (73% 

No). Responses to 1g suggest that most operators do not place restrictions on use or 

stowage of wireless headsets (61% No). Responses to 1h suggest that about half of 

operators receive reports of passenger non-compliance with PED stowage policies 

(46% Yes). 

Question 2 asked about seat power plugs; responses suggest that most operators 

(37% Yes, 59% No) at this time do not have this option available to passengers. 

Responses to 2a suggest that most operators today who have power plugs do not 

allow unrestricted use of them during all phases of flight (10% Yes). Responses to 2b 

suggest that cabin crew can generally disable seat power if necessary (27% Yes); 

responses to 2c suggest that very few of these systems can be disabled at individual 

seats (5% Yes), although responses to 2d suggest that power can often be disabled 

in individual sections of the cabin (20% Yes). 

The remaining survey questions asked about crew announcements, stowage policy 

enforcement, and reports of injury incidents involving PEDs. The responses to 

question 3 indicate that operators, in general, require crewmembers to make 

announcements that relate to stowage of PEDs (80% Yes), while the responses to 

question 4 suggest that somewhat fewer operators (61% Yes) require that 

crewmembers follow specific procedures to enforce stowage policy restrictions on 

PEDs. Responses to question 5 suggest that few operators have reports of 

passengers being struck by PEDs during inflight incidents; only one responder 

definitively answered yes to this question, while 34% were unsure. 

   
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-19 

4. PED Stowage Considerations

The ARC report recommends that FAA and industry stakeholders develop standard content 

and timing for cabin and flight deck crewmember instructions to passengers on use and 

stowage of PEDs. 

The ARC report further recommends to support standardized industry best practices for 

stowage related to PEDs, the FAA update stowage policy and guidance documents to 

incorporate expanded use of PEDs as necessary. The information in this section provides 

ideas for operators to consider when reviewing their stowage policies. 

4.1. Key Issues to Consider

The Stowage Policy working group debated various issues related to stowage and 

securing of loose items in order to develop specific recommendations to the FAA for 

future research and development of guidance to operators. The issue that received 

the greatest attention: How to balance the desire of many passengers to use their 

PEDs during the critical takeoff and landing phases of flight while maintaining or 

even elevating existing levels of operational and occupant safety. Other issues 

explored included the effect of PED use on passenger attention to crewmember 

instructions during the pre-takeoff and pre-landing phases as well as emergency 

incidents; options for designating seat pockets as approved stowage locations 

without damaging their structural integrity, adversely affecting egress, and increasing 

projectile risks; safe use and stowage of corded devices (e.g., headphones, power 

adapters); management of under-seat stowage to prevent PEDs from becoming 

tripping or projectile hazards or obscuring emergency path markings; content and 

timing of crew announcements in combination with appropriate procedures and 

training to encourage passenger compliance with stowage policies and adequate 

management of loose item risks; and content, formats and media options for 

disseminating information to travelers that explain operator stowage policies in ways 

that maximize understanding and acceptance of restrictions. 

Roughly in parallel with these internal Stowage Policy working group discussions, 

research scientists in the FAA Office of Aerospace Medicine, Civil Aerospace 

Medical Institute (CAMI), Protection and Survival Research Laboratory (AAM-630) 

also assessed options for expanded PED usage policies. The AAM-630 

Memorandum in Appendix 2 of this document considers the relationship of PED 

usage to post-crash emergency evacuation; reviews literature on the adverse effects 

of distractions on passenger safety awareness and National Transportation Safety 

Board (NTSB) recommendations to counter historic declines in passenger attention 

to safety information; reviews accident data showing that take-off and landing are 

critical phases of flight for accidents and fatalities; praises the benefits of mandatory 

evacuation drills for all passengers on cruise ships; and supports the need for a 

clean cabin environment during pre-flight briefings and critical phases of flight. 

 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-20 

The AAM-630 memorandum also considers the issues of projectile injury risks from 

unsecured items of mass, items in seat pockets, and items held in a cabin occupant’s 

hand. AAM-630 research scientists state in the memorandum that it is the unexpected 

nature of events such as turbulence and emergency landings that makes it unlikely a 

passenger would be able to hold onto an object during an incident, even if it is small 

and light. The memorandum also comments on the lack of evidence for any increased 

occupant injury risk posed by PEDs when compared to “any other object (e.g., a hard 

cover book) of similar weight, size and stiffness.” (p. 4 of Appendix 2) 

The AAM-630 memorandum concludes with a discussion of dynamic testing of airplane 

seats with 3 lbs of paper, approximately 1.25 inches thick, stowed in a seat pocket 

during the seat qualification process. The memorandum response suggests that 

“dynamic tests show that the seat can carry the additional weight of the literature 

without structural failure, but do not ensure that the literature is retained throughout the 

entire dynamic event” (reference Appendix 2, pages 4-5). 

This last observation referenced in the AAM-630 memorandum, which concerns the 

lack of testing to ensure that contents in seat pockets are retained, is supported by a 

summary of one aircraft manufacturer’s policy related to dynamic seat testing obtained 

by a member of the Stowage Policy working group. This testing policy, which conforms 

to applicable sections of SAE Aerospace Standard 8049B (referenced in footnote 29 of 

the AAM-630 memorandum) may be summarized as follows: 

• Dynamic Testing of the passenger seats is to validate that the seat can take the 

weight of its occupant plus the weight of a 3 lb. object stored in the seat pocket. 

• Dynamic Testing does not prove that the 3 lb. object stays in the seat pocket, 

there are no requirements for this. 

• There is no requirement that defines the size of the object to be used during the 

testing....just that it weigh 3 lbs. 

• Prior to the testing, the seat pocket is "taped" shut so the 3 lb. object remains in 

the pocket during the test.

 
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Appendix G: PED Stowage Policy Assessment & Considerations Page G-21 

4.2. Key Questions

The Stowage Policy working group reviewed the regulatory and guidance material in 

Section 2 and the policy survey responses in Section 3, along with the Appendix 2 

memorandum prepared by AAM-630. As a result of this review, the following 

questions arose: 

• What are the impact injury risks, assessed qualitatively and quantitatively, 

from typical PEDs of less than 3 pounds, in the event of a survivable 

impact on takeoff or landing?66 Are PEDs any different than books or 

magazines, in terms of occupant injury risks, considering such factors that 

could include, but are not limited to, weight, form factor, hardness, and 

quantity? 

• Is there an acceptable size/weight limitation for PEDs that could allow 

stowage in seat pockets during critical phases of flight? Is 3 lbs an 

acceptable weight constraint? Should the allowable weight account for an 

operator’s existing seat pocket contents (i.e., magazines, safety briefing 

cards, and airsickness bags)? Figure 1 shows one possible concept for a 

seat pocket PED sizing card – would such a concept be useful in tandem 

with an operator’s stowage policy? 

• How can operators further improve cabin safety policies so that the 

expansion of PED use during all phases of flight does not adversely affect 

the safety of the travelling public? 

• Would the allowed use of PEDs through all phases of flight impact cabin 

safety? (Refer to Figure 2 below) If safety were affected, how should 

operators update policy to mitigate any reduction of safety? 

• How can the use of seat power receptacles be managed with an 

expansion of PED usage? Can a PED adversely restrict egress in an 

emergency evacuation if plugged into aircraft power receptacles? 

• Can a PED adversely restrict egress in an emergency evacuation if 

stowed in a seat pocket – assuming all items in seat pocket do not 

exceed 3 lbs.? If so, is there an acceptable maximum device size? 

• Can a PED with thin form factors (e.g., tablets, laptops) adversely restrict 

egress in an emergency evacuation if stowed under a seat outside of a 

bag? 

• In the event of tarmac delays or runway holds when the airplane is not 

moving, should flight deck crewmembers authorize that passenger PEDs 

(including larger devices such as laptops) be used? 

   

                                                            

66 Static inertial forces as specified by 14 CFR § 25.561(b)(3). 

 Hyperlink: §25.561 Structures, General [http://www.ecfr.gov/]; Accessed September 19, 2013. 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-22 

Figure 1. Stowage Policy Example for a PED Size Check Box 

Sample dimensions and PED weight limits are one way (but not the only way) for passengers to 

quickly determine if their device is permitted by an operator's policy. Aircraft operators would 

determine appropriate values based on their fleet composition and best judgment. 

• Specific dimensions and stowage policy 

(e.g., FAA approved carry-on baggage program 

which includes personal items, and/or personal 

items policy for those carriers that do not have 

an FAA approved carry-on baggage program) to 

be developed by the aircraft operator and 

approved by the geographic responsible FAA 

certificate oversight office. 

• The aircraft operator is ultimately responsible for 

the specifics of what is displayed on the PED 

gate sizing box. There will be some variance 

based on the uniqueness of the air carrier’s 

operations and aircraft. 

NOTE: FAA InFO 09018 – Stowage of Items in 

Seat Pockets, explains seat pockets have 

been designed to restrain approximately 3 

pounds of weight and not the weight of 

additional carry-on items. The PED weight 

limit should take into consideration aircraft 

conformity items in the seat pocket e.g. 

briefing card, air sickness bag, inflight 

magazine (which contains safety and 

compliance information for passengers), 

headset that plugs into the armrest. 

Figure 2. Phases of Flight 

   

1 2 3 4 5 6 7 8

Parked Taxi Takeoff &

Departure

takeoff to

transition‐to‐

climb altitude

and/or gear

up

Climb Cruise Descent

to IAF

and/or flaps

Approach

IAF or flaps

to visual

reference to

landing

Landing

&  

Taxi to

Gate

10’000 AGL 10’000 AGL
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-23 

4.3. Minimize Variability of Stowage Policies

The variability of PED stowage policies between operators should be minimized, in 

order to maximize passenger understanding and acceptance of the rules, as well as 

compliance with crewmember instructions. 

4.4. Develop a Public Messaging Strategy

The information to the traveling public on cabin stowage policies should be easy to 

understand, concise, and be widely disseminated through various forms of media. 

   
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-24 

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations 

Appendix 1: PED Stowage Survey ResponsesNote: Appendix 1 has been formatted for electronic viewing and may also be printed on 11" x 17" paper.

05

10152025303540

Does your

aircraft

operation have

a policy

requiring

stowage ofsome or all

passenger

PEDs at any

point during a

flight? If Yes,

please answer

questions 1a‐

h, and attach

text of policy,

if possible.

Does the

policy require

stowage of

passenger

PEDs under

some flight

conditions

and/or phases

of flight?

Does the

policy treat

different sizes

and/or weights

of passenger

PEDs

differently?

Does the

policy allow

passenger

PEDs to be

stowed in seat

back pockets?

Does the

policy limit the

weight of

items,

including

passenger

PEDs, stowed

in seat back

pockets?

Does the

policy limit

seat back

pocket

stowage to

ensure that

passengers can

egress safely

during an

emergency?

Does the

policy

speci ficallyrestrict the

use/stowage

of wired

headsets?

Does the

policy

speci ficallyrestrict the

use/stowage

of wireless

headsets?

Does your

aircraft

operation have

crewmember

reports of

incidents

involving

passenger

Non‐

compliance

with PED

stowage

requirements?

If Yes, please

attach

examples, if

possible.

Do any of your

aircraft have

seat power

plugs installed

for passenger

use? If Yes,

please answer

questions 2a‐

b.

Can passenger

PEDs be

connected to

seat power

during all

phases o f

flight?

C

crew

dis

pow

plea

que

1 1a 1b 1c 1d 1e 1f 1g 1h 2 2a 

Yes 38 36 21 25 28 34 7 10 19 15 4 No 3 4 17 15 6 4 30 25 7 24 12 BLANK 0 1 2 1 6 3 3 5 15 2 25 OTHER 00101011000

Total Number of Response ‐ 41

ResponsestoQuestions
A Report from

Appendix 

Qu

Que

m the PED AR

G: PED Stowa

42%

Do

Does

uestion ‐ 1

estion – 1b

RC to the FAA

age Policy Asse

%

oes the poli

s your aircra

essment & Con

5% 2

icy treat dif

7%

aft operatio

passenger P

nsiderations 

2%

fferent sizes

differ

0% 0%

on have a p

PEDs at any

s and/or we

ently?

93%

%

policy requir

y point duri

51

eights of pa

ring stowag

ing a flight?

1%

assenger PE

ge of some

?

EDs

YesNoBLANOTHE

or all

YesNoBLANOTHE

NK

ER

NK

ER

Quest

Questio

Does the po

ion – 1a

n – 1c

10%

olicy requ
A Report from

Appendix 

Que

Ques

m the PED AR

G: PED Stowa

Do

estion – 1d

stion – 1f

RC to the FAA

age Policy Asse

es the polic

essment & Con

73%

7% 3

cy specifica

nsiderations 

%

lly restrict t

17

he use/sto

7%

wage of wired headsets?

YesNoBLANOTHE

K

R

QuestioQuestio

Does the

Does the

on – 1eon – 1g

6

12%

e policy s

10%

policy lim
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations 

10%

29%

61%

0%

Can passenger PEDs be connected to seat power during all phases of flight?

YesNoBLANKOTHER

58%

Do any of your ai

46%

17%

37%

0%

Does your aircraft operation have crewmember reports of incidents involving

passenger Non‐compliance with PED stowage requirements?

YesNoBLANKOTHER

Question – 1h Question – 2Question – 2a

61%

Can 

Question – 2b
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations 

5%

29%

63%

3%

Can cabin crewmembers disable seat power at individual seats?

YesNoBLANKOTHER

63%

Can cabin crewmemb

80%

20%

0% 0%

Are crewmembers (pilots and/or flight attendants) required to make

announcement(s) to passengersrelated to stowage of PEDs?

YesNoBLANKOTHER

Question – 2c Question – 2d

Question – 3

32%

Does your aircra

attendants) follow 

Question – 4
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations 

3%

63%

34%

0%

Does your aircraft operation have reports of passenger PEDs thrown about the

cabin due to turbulence, hard landing, or sudden stop

acceleration/deceleration?

YesNoBLANKOTHER

Question – 5
A Report from

Appendix 

Append

AAM‐63

m the PED AR

G: PED Stowa

dix 2:		

30 Memora

RC to the FAA

age Policy Asse

ndum, Rec

ssment & Con

ommendat

siderations

ions for PED Usage Onboard Ai

Page

rliners

 G-31 
A Report from

Appendix 

the PED AR

G: PED Stowa

C to the FAA

age Policy Assessment & Considerations Page G-32 
A Report from

Appendix 

m the PED AR

G: PED Stowa

C to the FAA

age Policy Assessment & Considerations Page G-33 
A Report from

Appendix 

the PED AR

G: PED Stowa

C to the FAA

age Policy Assessment & Considerations Page G-34 
A Report from

Appendix 

m the PED AR

G: PED Stowa

C to the FAA

age Policy Assessment & Considerations Page G-35 
A Report from the PED ARC to the FAA

Appendix G: PED Stowage Policy Assessment & Considerations Page G-36 

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix H: Passenger Use Survey Data Page H-1 

APPENDIX H:		 PASSENGER USE SURVEY DATA

Appendix H includes passenger use survey data reviewed by the PED ARC during its 

deliberations. The following information was compiled and prepared for publication by the 

member organization listed. 

• Airline Passenger Experience Association & Consumer Electronics Association, Portable 

Electronic Devices on Aircraft Study (March 2013) 

• Consumer Electronics Association, CEA Comparison Summary Report - Portable 

Electronic Devices on Aircraft - 2003 vs. 2013 (April 2013) 

• Delta Air Lines, Customer Service Data (October 2012) 
A Report from the PED ARC to the FAA

Appendix H: Passenger Use Survey Data Page H-2 

(intentionally left blank) 
Portable Electronic Devices on Aircraft

Joint study created in collaboration with 

the Airline Passenger Experience Association 

and the Consumer Electronics Association (CEA)®
Federal copyright law prohibits unauthorized reproduction of this report by any 

means. Any text, data, charts, or other material used from this report must be 

sourced from Airline Passenger Experience Association and the Consumer 

Electronics Association.
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 1 

Table of Contents

Methodology............................................................................................................ 1

Background and Research Objectives........................................................................... 2

Executive Summary.................................................................................................. 3

Detailed Findings..................................................................................................... 5

Airline Travel and Portable Electronic Device Usage............................................................... 5

Importance of Staying Connected While Traveling .................................................................. 11

Understanding of Allowed PED Usage While on Aircraft........................................................... 13

Concern About the Safety of PED Usage on Aircraft................................................................ 17

Interest in and Likelihood to Purchase In-Flight Wi-Fi Service................................................... 19

Interest in Expanded PED Usage and Ability to Make Cell Phone Calls on Aircraft......................... 23

Conclusions............................................................................................................. 26
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 2 

Methodology

The report described herein was designed and formulated jointly by the Consumer Electronics 

Association (CEA) ® and the Airline Passenger Experience Association (APEX). This report presents the 

findings of a telephone survey conducted among two national probability samples, which, when 

combined, consist of 1,629 adults, 815 men and 814 women 18 years of age and older, living in the 

continental United States. Interviewing for this CARAVAN® Survey was completed on December 14-18, 

2012. 1,093 interviews were from the landline sample and 536 interviews from the cell phone sample. 

 

The margin of sampling error at 95% confidence for aggregate results is +/- 2.43%. Sampling error is 

larger for subgroups of the data. As with any survey, sampling error is only one source of possible error. 

While non-sampling error cannot be accurately calculated, precautionary steps were taken in all phases 

of the survey design, collection and processing of the data to minimize its influence.

 

During the fielding of this study, Consumer Electronics Association (CEA) ® and the Airline Passenger 

Experience Association (APEX) employed the services of Opinion Research Corporation (ORC) to 

conduct telephone interviewing. The telephone interviewing employed industry standard random-digit 

dialing and computer assisted telephone interviewing (CATI). 

 

Sampling

ORC's CARAVAN® landline-cell combined sample is a dual frame sampling design. This means that the 

sample is drawn from two independent non-overlapping sample frames—one for landlines and one for 

cell phones.

 

Land Line Sample

ORC’s Random Digit Dial (RDD) telephone sample is generated using a list-assisted methodology. 

 

Cell Phone sample

The MSG Cellular RDD database is constructed quarterly utilizing Telecordia’s LERG product. 

As is common practice in survey research, the data was weighted to reflect the known demographics of 

the population under study. In this survey, weights were applied to cases based on gender, age, race and 

geographic region. As a result, this data can be generalized to the entire U.S. adult population.

The bases shown on all charts and tables are weighted bases. All percentages in the text, charts and 

tables included in this report are also based on weighted data.

 

The Consumer Electronics Association is a member of the Marketing Research Association (MRA) and 

adheres to the MRA’s Code of Marketing Research Standards.

 

CEA and APEX designed this study in its entirety and is responsible for all content contained in this 

report. Any questions regarding the study should be directed to CEA Market Research staff at 

info@CE.org.
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 3 

Background and Research Objectives

The Federal Aviation Administration (FAA) has policies in place that permit the usage of specified 

portable electronic devices (PED) that the aircraft operator has determined will not interfere with the safe 

operation of the aircraft. These regulations generally prohibit the use of all PEDs during taxiing, take-off 

and landing. However, with the recent proliferation of PEDs such as smartphones, tablets and e-Readers

into travelers’ Internet-connected lives, many passengers, along with various industry groups and 

associations, are leading initiatives asking for greater usage of PEDs while on aircraft.

The objectives of this study are to gauge consumer awareness and usage of PEDs on aircraft by: 

 Assessing current consumer awareness and perceptions of the safety of PEDs on aircraft

 Evaluating existing and future usage of PEDs on aircraft
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 4 

Executive Summary

 Nearly all (94%) U.S. adult airline passengers have brought at least one PED with them onto an 

aircraft while traveling in the past 12 months, either in their checked baggage or as a carry-on 

item. 

o The majority of PEDs brought on aircraft are carried-on. The most common PEDs 

carried-on include smartphones, notebook or laptop computers and basic cellphones, 

while the most frequently checked PEDs include notebook or laptop computers, 

smartphones and portable digital audio or MP3 players.

 Seven in ten (69%) PED carrying passengers report they used their device(s) during the flight, 

with the most commonly used devices being smartphones, notebook or laptop computers, tablet 

computers or digital audio or MP3 players. 

o During their flight, passengers most often use their PEDs for entertainment purposes: 

listening to music, playing games, reading books or magazines and watching movies, TV 

or videos. There are also a number of passengers who work while in-flight by working 

offline, reading email, sending email or working online. 

 While on the ground, either prior to take-off or after landing, communication appears to be key. 

More than eight in ten (85%) passengers reported they used their PED(s) prior to take-off or after 

landing, the majority of use being of smartphones and basic cell phones. 

o Sending text messages is the number one activity conducted by passengers while on the 

ground, followed by reading email, listening to music, connecting to Wi-Fi (if available), 

sending email and playing games. 

 In addition to their own PED usage on airplanes, four in ten (42%) passengers report their travel 

companions, such as family members, have also used PED(s) during flight(s) in the past 12 

months. 

o Smartphones and tablet computers are the PEDs most commonly used by these travel 

companions, devices likely used for entertainment purposes such as playing games, 

listening to music, reading books or magazines or watching movies, TV or videos. 

 Four in ten (43%) passengers indicate they would like to be able to use PEDs during all phases of 

flights, including take-off and landing. 

 However, six in ten (61%) airline passengers believe that making cell phone calls should be 

restricted during flights, mainly due to the potential distractions it could cause for other 

passengers.

 Six in ten (61%) passengers feel it is important to be able to use their PEDs when flying for 

personal reasons. Interestingly, a considerably lower 43% feel the same is true for business 

travel, and about half (51%) feel it is important to be able to use PEDs when flying for business 

and personal purposes combined, suggesting that PED usage for entertainment purposes is 

more important than usage for work-related purposes. 

 The importance of actually being able to connect PEDs to the Internet is considerably lower than 

the importance of having the device while traveling, further supporting the notion that PED usage 

for entertainment purposes is more important than usage for work-related purposes. 

Approximately four in ten agree it is important to be able to connect their PEDs to the Internet 

while traveling for personal (39%), combined business and personal (37%) and business 

purposes (35%) alike. 

 While the majority of passengers say they follow clear and proper instruction on allowed usage of 

PEDs prior to take-off, the data shows this is not always the case. More than nine in ten (94%) 

passengers agree the instructions are clear, yet only six in ten (59%) say they always turn their 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 5 

devices completely off when asked to do so, with an additional 5% who say they sometimes turn 

their devices completely off. 

 Almost one third (30%) of passengers report they have accidently left a PED turned on during a 

flight. Smartphones, the most common PEDs carried onto passenger planes, are also the most 

common PED to be accidently left turned on. 

o Basic cellphones, tablet computers and digital audio/MP3 players are also accidently left 

on occasionally. 

 Additionally, many passengers do not have a clear understanding of specifically when their PEDs 

can be used on an aircraft. Four in ten (43%) passengers incorrectly believe it is acceptable to 

use PEDs while taxiing to the runway, 32% while in the air before reaching 10,000 feet and 26% 

while the plane is in its final descent.

 Six in ten passengers are concerned about the potential for interference caused by PEDs

powered on during both take-off (60%) and landing (58%). 

o Passenger concern is not nearly as high for devices powered on while in-flight or for 

devices left in airplane mode. 

o Reasons for this concern vary, but mainly center around interference and safety in 

general.

 More than half (57%) of passengers express interest in in-flight Wi-Fi services, while one-third 

(34%) are not interested.

o Notebook or laptop computers, smartphones and tablet computers top the list of devices 

passengers would like to be able to connect to the Internet during flight.

 Passengers are more likely to purchase Wi-Fi when on longer flights. If available on a flight and 

reasonably priced, passengers are most likely to purchase Wi-Fi in-flight if the flight is over three 

hours in length (57% likely). Conversely, they are least likely to purchase if the flight is less than 

three hours long (32%). The purpose of the trip, business versus personal versus combined, does 

not make much of a difference in likelihood to purchase, as approximately four in ten would 

purchase for any of said travel purposes.
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 6 

Detailed Findings

Airline Travel and Portable Electronic Device Usage

One in five (20%) U.S. adults have taken a flight for personal reasons in the past 12 months. An 

additional 7% have flown for business purposes and 4% for combined business and personal purposes. 

Passengers who flew for business took an average of seven flights in the past 12 months. Looking 

specifically at those who flew for personal reasons, five flights were taken in the past 12 months, while 

combined business and personal flyers averaged four flights. Females are more likely than males to have 

taken personal flights, while males and passengers ages 35-54 are more likely to have taken business 

flights.

2%

94%

0%

4%

4%

2%

78%

4%

16%

20%

2%

91%

2%

4%

7%

Don't know

None

6 or more

1 to 5

Any (net)

Number of Airline Flights Taken in Past 12 Months -- % of Respondents --

Business Personal Combined Business & Personal

Average Number of 

Flights

(among those who have flown

for specific reasons in the past 

12 months)

7.3 Business

4.9 Personal

4.3 Combined

Figure 1

Base=U.S. adults (n=1,629)

Q. In the PAST 12 MONTHS, how many airline FLIGHTS have you, personally, taken where the purpose of travel was for each of 

the following. Please count each individual flight, including direct and connecting flights.
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 7 

Nearly all (94%) passengers have brought at least one PED with them onto an aircraft while traveling in 

the past 12 months, either in a checked baggage or as a carry-on item. The majority of PEDs brought on 

aircraft are carried-on. Among those who have flown in the past 12 months and who have brought PEDs 

with them while flying, 99% carried-on at least one device and 17% checked at least one device in their 

baggage. The most common PEDs carried-on include smartphones (63%), notebook or laptop computers 

(45%) and basic cellphones (31%), while the most frequently checked PEDs include notebook or laptop 

computers (8%), smartphones (6%) and portable digital audio or MP3 players (5%).

82%

1%

2%

4%

3%

2%

3%

5%

2%

8%

6%

17%

1%

4%

6%

13%

16%

14%

27%

28%

31%

45%

63%

99%

None of these

Portable game device

Portable DVD player

Bluetooth devices

Noise-cancelling headphones

e-Reader

Tablet computer

Portable digital audio or MP3 player

Cell phone that is not a smartphone

Notebook or laptop computer

Smartphone

Any portable device (net)

Devices Brought on Airplane While Traveling in Past 12 Months 

Mentions of 5% or More

-- % of Respondents --

% as Carry-on

% in Checked Baggage

Figure 2

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Which, if any, of the following portable electronic devices have you brought with you when traveling by airplane in the PAST 12 

MONTHS? 

Base=U.S. adults who have taken any flights in the past 12 months and who have brought portable electronic devices with them 

while flying (n=353) 

Q. Of those portable electronic devices you have brought with you while traveling by airplane in the past 12 months, which ones 

did you... A.) take on the plane with you? B.) put in your checked baggage?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 8 

While on the airplane, seven in ten (69%) PED carrying passengers report they used their device(s) 

during the flight, with 85% using their PED(s) prior to take-off or after landing. While in-flight, roughly one 

quarter of these passengers used their smartphone (28%), notebook or laptop computer (25%), tablet 

computer (23%) or their digital audio or MP3 player (23%). While on the ground, communication appears 

to be key; the most commonly used PEDs prior to take-off or after landing are smartphones (55%) and 

basic cell phones (23%). 

Devices Personally Used on Airplane While Traveling in Past 12 Months

Mentions of 5% or More

-- % of Respondents --

During the Flight Prior to Take-Off or 

After Landing

Any portable electronic device (net) 69% 85%

Smartphone 28% 55%

Notebook or laptop computer 25% 19%

Tablet computer 23% 16%

Portable digital audio or MP3 player 23% 15%

e-Reader 13% 7%

Noise-cancelling headphones 12% 5%

Cell phone (non-smartphone) 5% 23%

Portable DVD player 5% 3%

Bluetooth devices 3% 5%

None of these 31% 15%

Figure 3

Base=U.S. adults who have taken any flights in the past 12 months and who have brought any listed portable electronic 

devices with them on the plane while flying (n=348) 

Q. And which of those portable electronic devices have you personally USED while on the airplane... A.) during the flight B.) 

prior to take off or after landing
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 9 

What do airline passengers use their PEDs for while flying? During flight, passengers are most often 

entertaining themselves by listening to music (68%), playing games (54%), reading books or magazines 

(48%) and watching movies, TV or videos (44%). There are also a number of passengers who tend to 

work in-flight, with 39% working offline, 31% reading email, 23% sending email and 19% working online. 

4%

2%

7%

18%

19%

23%

23%

24%

30%

31%

39%

44%

48%

54%

68%

None of these

Other

Shop online

Browse social media channels

Online work

Send email

Text message

Take pictures or videos

Connect to Wi-Fi (if available)

Read email

Offline work

Watch movies / TV / videos

Read books or magazines

Play games

Listen to music

Specific Usage of PEDs During Flight -- % of Respondents --

Figure 4

Base=U.S. adults who have taken any flights in the past 12 months and who have used any listed portable electronic devices 

brought on the plane with them during the flight (n=239) 

Q. What functions do you personally use your portable electronic devices for while on the airplane during the flight? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 10 

While on the ground, either before taking off or after landing, work and entertainment co-mingle at the top 

of the list of activities reported by PED users. Sending text messages (61%) is the No. 1 activity, followed 

by reading email (43%), listening to music (42%), connecting to Wi-Fi (if available) (40%), sending email 

(38%) and playing games (37%).

12%

5%

9%

23%

25%

26%

27%

29%

31%

37%

38%

40%

42%

43%

61%

None of these

Other

Shop online

Online work

Watch movies / TV / videos

Browse social media channels

Take pictures or videos

Read books or magazines

Offline work

Play games

Send email

Connect to Wi-Fi (if available)

Listen to music

Read email

Text message

Specific Usage of PEDs Prior to Take-Off or After Landing -- % of Respondents --

Figure 5

Base=U.S. adults who have taken any flights in the past 12 months and who have used any listed portable electronic devices 

brought with them prior to take off or after landing (n=296) 

Q. What functions do you personally use your portable electronic devices for while on the airplane prior to take off or after 

landing? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 11 

In addition to their own PED usage on airplanes, four in ten (42%) passengers report travel companions, 

such as family members, also using PED(s) during flight(s) in the past 12 months. Travel companions 

most commonly use smartphones (24%) and tablet computers (14%), devices likely used for 

entertainment purposes such as playing games, listening to music, reading books or magazines or 

watching movies, TV or videos. 

57%

2%

2%

4%

4%

5%

7%

9%

9%

14%

24%

42%

None of these

Portable game device

Bluetooth devices

Portable DVD player

Cell phone (non-smartphone)

e-Reader

Noise-cancelling headphones

Digital audio / MP3 player

Notebook or laptop computer

Tablet computer

Smartphone

Any portable device (net)

Devices Used by Travel Companion(s) on Airplane While 

Traveling in Past 12 Months -- % of Respondents --

Figure 6

Base=U.S. adults who have taken any flights in the past 12 months and who have brought any listed portable electronic 

devices with them while flying (n=348) 

Q. Which were used by others, such as family members, traveling with you while on the airplane?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 12 

Importance of Staying Connected While Traveling

Six in ten (61%) passengers feel it is important to be able to use their PEDs when flying for personal 

reasons. Interestingly, a considerably lower 43% feel the same is true for business travel, while about half 

(51%) feel it is important to be able to use PEDs when flying for business and personal purposes 

combined. This discrepancy in importance may be due to personal travelers wanting PEDs available for 

entertainment purposes, while business travelers may not want their PEDs with them so they don’t feel 

obligated to work while on the plane. 

Notably, passengers ages 35-54 are more likely to consider the use of PEDs while on flights for business 

or for personal purposes to be important than are passengers ages 55+. Additionally, those ages 25-54 

are more likely to consider the use of PEDs while on flights for combined business and personal reasons 

to be important when compared to those 55+.

 

6%

5%

34%

24%

17%

8%

8%

6%

9%

12%

14%

9%

16%

16%

34%

35%

45%

Business

Combined Business &

Personal

Personal

Importance of Being Able to Use Portable Electronic Devices 

While Traveling

-- % of Respondents --

Not applicable Not at all important Not very important

Neutral Somewhat important Very important

% Somewhat + 

Very Important

61%

51%

43%

Figure 7

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. How important is it to you to be able to use portable electronic devices while traveling for each of the following purposes? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 13 

Importance of actually being able to connect PEDs to the Internet is considerably lower than the 

importance of having the devices while traveling, suggesting that PED usage for entertainment purposes 

is more important than usage for work-related purposes. Approximately four in ten agree it is important to 

be able to connect PEDs to the Internet while traveling for personal (39%), combined business and 

personal (37%) and business purposes (35%) alike. 

Notably, passengers ages 35-44 are more likely to feel it is important to be able to connect their PEDs to 

the Internet while flying for business purposes or for business and personal purposes combined, more so 

than their counterparts ages 25-34 or 55+. In addition, male passengers are more likely than female 

passengers to assign higher importance to being able to connect their PEDs to the Internet while flying for 

business purposes. 

5% 39%

32%

31%

6%

9%

10%

15%

18%

18%

10%

13%

8%

25%

24%

31%

Business

Combined Business &

Personal

Personal

Importance of Being Able to Connect Portable Electronic 

Devices to the Internet While Traveling -- % of Respondents --

Not applicable Not at all important Not very important

Neutral Somewhat important Very important

% Somewhat + 

Very Important

39%

37%

35%

Figure 8

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. How important is it to you that your portable electronic devices be connected to the internet while traveling for each of the 

following purposes? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 14 

Understanding of Allowed PED Usage While on Aircraft

While the majority of passengers feel they receive clear and proper instructions on the allowed usage of 

PEDs prior to take-off, the data show this is not always the case. More than nine in ten (94%) passengers 

agree the instructions are clear, yet only six in ten (59%) say they always turn their devices completely 

off when asked to do so, with an additional 5% who say they sometimes turn their devices completely

off. If so many passengers understand the instructions given to them, why don’t they turn their devices off 

when instructed to do so? Some may honestly forget – perhaps they have a device in their carry-on bag 

that they overlooked. Others simply choose not to, evidenced by the 21% of passengers who say they 

turn their devices to airplane mode and the 2% who store their devices, but do not turn them off.

Of particular interest, more passengers ages 25-34 are defiant and turn their devices to airplane mode 

than are the more rule-abiding passengers ages 55+, who are also more likely to not use PEDs while 

traveling than are their counterparts ages 25-54. 

Yes

94%

No

5%

Don't 

know

1%

Are Clear and Proper 

Instructions Given 

Regarding Usage of 

PEDs? -- % of Respondents --

13%

2%

5%

21%

59%

64%

Do not use portable

electronic devices while

flying

Store your devices, but do

not turn them off

Sometimes turn your

devices completely off

Turn your devices to

'airplane mode'

Always turn your devices

completely off

Always / sometimes turn

your devices completely off

(net)

Action Taken When Instructed to 

Turn Portable Electronic Devices to 

the Off Position

-- % of Respondents --

Figure 9

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Do you think clear and proper instructions are given by the flight attendants prior to take-off about the usage of portable 

electronic devices while on the airplane? 

Q. When instructed to turn your portable electronic devices ‘to the off position' before take-off or landing, which of the following 

best describes how you respond to these instructions? Would you say... 

 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 15 

Almost one third (30%) of passengers report they have accidently left a PED turned on during a flight. 

Smartphones, which are the most common PEDs carried onto planes with passengers, are also the most 

common PED accidently left turned on. Basic cellphones (18%), tablet computers (16%) and digital 

audio/MP3 players (13%) are also left on occasionally, though not nearly as often as smartphones.

Passengers ages 35-54 are more likely to have accidently left a PED turned on during a flight when 

compared to those 55+, which aligns nicely with the fact that passengers 55+ are less likely to be using

PEDs while flying, making them less likely to leave one turned on.

Additionally, many passengers do not have a clear understanding of when their PEDs can be used while 

on an aircraft. Current rules and regulations require PEDs to be stored and completely powered off during 

the following times: while on the ground taxiing to the runway, in the air before reaching cruising altitude 

(10,000 feet) and during the final descent. However, four in ten (43%) passengers incorrectly believe it is 

okay to use their PEDs while taxiing to the runway, 32% while in the air before reaching 10,000 feet and 

26% while the plane is in its final descent, indicating that some passengers are likely using their devices 

during these PED-restricted times.

Yes

30%

No

67%

Don't 

know

4%

Incidence of Accidently 

Leaving PED Turned on 

During a Flight 

-- % of Respondents --

3%

3%

4%

6%

7%

7%

13%

16%

18%

61%

Don't know

Portable game device

Bluetooth devices

Noise-cancelling

headphones

e-Reader

Notebook or laptop

computer

Digital audio / MP3 player

Tablet computer

Cell phone (nonsmartphone)

Smartphone

Devices Accidently Left Turned on 

During a Flight -- % of Respondents That Accidently Left a 

PED devices Turned On During a Flight --

Figure 10

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Have you ever accidentally left any of your portable electronic devices TURNED ON during a flight? 

Base=U.S. adults who have taken any flights in the past 12 months and who have accidently left any listed portable electronic 

devices turned on during a flight (n=110) 

Q. Which of the following devices have you accidentally left TURNED ON during a flight? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 16 

Understanding of When Portable Electronic Devices Can be Used 

While on an Airplane

On the 

ground, 

before 

the 

doors 

close

On the 

ground, 

while 

taxiing 

to the 

runway

In the 

air, 

before 

reaching 

10,000 

feet

In the 

air, after 

reaching 

10,000 

feet

During 

the 

initial 

descent

During 

the 

final 

descent

After 

landing, 

while 

taxiing 

to the 

gate

Any PEDs are 

allowed (net) 89% 43% 32% 73% 33% 26% 73%

Cell phone (nonsmartphone) 73% 21% 6% 36% 8% 6% 54%

Smartphone 72% 21% 9% 45% 9% 7% 58%

Portable digital 

audio / MP3 player 71% 29% 16% 61% 18% 10% 52%

e-Reader 70% 25% 15% 61% 15% 9% 50%

Tablet computer 70% 21% 11% 59% 13% 7% 48%

Portable DVD 

player 68% 23% 14% 59% 16% 7% 47%

Notebook or laptop 

computer 68% 22% 12% 63% 11% 6% 47%

Portable game 

device 67% 24% 13% 58% 15% 9% 47%

Noise-cancelling 

headphones 66% 31% 23% 57% 23% 18% 50%

Portable Blu-ray 

Disc player 64% 23% 12% 58% 14% 8% 47%

Bluetooth devices 62% 20% 8% 41% 9% 7% 45%

No PEDs are 

allowed 5% 48% 57% 18% 59% 67% 20%

Don’t know 5% 8% 11% 9% 9% 7% 7%

Passengers also show confusion over approved locations for PEDs during take-off and landing. During 

taxiing, take-off and landing, the times when PED usage is not allowed on aircraft, passengers are 

instructed to safely stow their PEDs underneath the seat in front of them or in the overhead bin. However, 

only 68% and 64% of passengers identified underneath the seat in front of them or in an overhead bin, 

respectively, as approved locations.

Figure 11

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. To the best of your knowledge, which of the following portable electronic devices can be used while on an airplane during the 

following times?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 17 

2%

1%

2%

22%

53%

56%

64%

68%

Don't know

None of these

Other

On your lap

Stowed underneath your seat

In the seatback pocket in front of you

Stowed in an overhead bin

Stowed underneath the seat in front of

you

Understanding of Where Portable Electronic Devices are 

Allowed to be Placed While on an Airplane

-- % of Respondents --

Figure 12

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. As you currently understand it, where are portable electronic devices allowed to be placed during take-off, approximately the 

first 30 minutes of a flight, and landing, the last several minutes of a flight?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 18 

Concern About the Safety of PED Usage on Aircraft

Six in ten passengers are concerned about potential interference from PEDs powered on during both 

take-off (60%) and landing (58%). Passenger concern is not nearly as high for devices powered on while 

in-flight or for devices left in airplane mode. The level of concern is lowest for devices in airplane mode 

while in-flight with only one quarter (26%) either somewhat or very concerned.

Notably, those over age 55 are more likely to be concerned with the likelihood of interference from PEDs 

left in airplane mode during take-off, landing and while in the air than are some of their younger 

counterparts. Additionally, female passengers are more concerned with PED left in airplane mode while 

in-flight than are male passengers.

35%

28%

26%

27%

19%

19%

22%

15%

15%

15%

10%

8%

16%

16%

14%

13%

12%

12%

14%

21%

18%

21%

29%

30%

12%

18%

25%

23%

29%

30%

In airplane mode in-flight

Powered on in-flight

In airplane mode during landing

In airplane mode during take-off

Powered on during landing

Powered on during take-off

Level of Concern With the Potential for Portable Electronic 

Devices to Interfere With Aircraft Communication and Navigation 

Equipment -- % of Respondents --

Don’t know Not at all concerned Not very concerned

Neutral Somewhat concerned Extremely concerned

% Somewhat 

+ Very

Concerned

60%

58%

44%

43%

39%

26%

Figure 13

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. How concerned are you about the potential for portable electronics devices to interfere with aircraft communication and 

navigation equipment if they are each of the following? Would you say extremely concerned, somewhat concerned, neutral, not 

very concerned or not at all concerned? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 19 

Reasons for this concern vary, but mainly center around interference and safety in general, which go 

hand-in-hand on aircraft. Interference with the pilot’s communication (17%) is the top reason for concern 

over PEDs on aircraft, followed by other safety concerns. 

Reasons for Concern About Potential Interference Caused by PEDs on Aircraft

Mentions of 5% or More

% of Respondents

Interference (net) 48%

 Could interfere with pilot's communication 17%

 Could interfere with navigation equipment 8%

 Could interfere with take-off or landing 6%

 Could interfere with communication (unspecified) 5%

 Possibility of interference (unspecified) 5%

Safety/Accident concerns (net) 24%

 Could cause plane crash / accident/injuries 13%

 Safety concerns / Want a safe flight 11%

That’s what you are instructed to do on a plane 8%

Concerned because not knowledgeable about what causes the problem 6%

There must be a reason why you are told to turn them off 6%

That’s what I’ve heard / been told 6%

Figure 14

Base=U.S. adults who have taken any flights in the past 12 months and who are concerned about the potential for PEDs to 

interfere with aircraft communication and navigation equipment (n=261) 

Q. Why are you CONCERNED about the potential for portable electronic devices to interfere with aircraft communication and 

navigation equipment?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 20 

Interest in and Likelihood to Purchase In-Flight Wi-Fi Service

More than half (57%) of passengers express interest in in-flight Wi-Fi services, while one third (34%) say 

they are not interested.

Passengers ages 25-54 express higher interest in the availability of in-flight Wi-Fi services than do 

passengers ages 55+, who logically would be less interested, again due to the lower incidence of this age 

group using PEDs while in-flight. Additionally, males are more likely to be ‘very interested’ than are 

female passengers.

24% 10% 8% 29% 28%

% of Respondents

Interest in In-Flight Wi-Fi Service 

Don't know Not at all interested Not very interested

Neutral Somewhat interested Very interested

Figure 15

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. As you may or may not know, some airlines are beginning to offer in-flight Wi-Fi service. How interested are you in in-flight Wi-Fi 

services offered by a commercial airline, such as American, Delta or United? Would you say... 

% Somewhat 

+ Very

Interested

57%
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 21 

The top devices passengers would like to connect to the Internet while traveling on aircraft are notebook 

or laptop computers (59%), followed by smartphones (55%), tablet computers (49%) and e-Readers 

(41%). 

Passengers ages 35-54 are considerably more likely to want to connect any PED to the Internet while 

flying than are their age 55+ counterparts, again likely due to the fact that those 55+ are less likely to use 

PEDs while on aircraft.

21%

24%

24%

26%

28%

30%

32%

36%

41%

49%

55%

59%

None of these

Portable Blu-ray Disc player

Bluetooth devices

Portable DVD player

Portable game device

Cell phone (non-smartphone)

Noise-cancelling headphones

Digital audio / MP3 player

e-Reader

Tablet computer

Smartphone

Notebook or laptop computer

Devices Passengers Would Like to be Able to Connect to the 

Internet During Flight

-- % of Respondents --

Figure 16

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Which of the following portable electronic devices would you like to be able to connect to the internet during flight?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 22 

Passengers are more likely to purchase Wi-Fi on longer flights. If available on a flight and reasonably 

priced, passengers are most likely to purchase Wi-Fi in-flight if the flight is over three hours (57% likely). 

Conversely, they are least likely to purchase if the flight is less than three hours long (32%). The purpose

of the trip, business versus personal versus combined, does not make much of a difference in likelihood 

to purchase, as approximately four in ten would purchase for any of said travel purposes.

Regardless of length of flight or for what purpose, passengers ages 25-54 are more likely to purchase WiFi in-flight than are those ages 55+, while males are more likely than females to be ‘very likely’ to 

purchase for business purposes and are more likely in total (somewhat + very likely) to purchase for 

combined business and personal flights.

6%

4%

42%

29%

37%

36%

35%

21%

9%

17%

13%

13%

4%

3%

3%

2%

4%

18%

24%

21%

20%

25%

14%

33%

19%

22%

18%

For flights less than 3 hours

For flights over 3 hours

For personal purposes

For business purposes

For combined business and

personal purposes

Likelihood to Purchase Wi-Fi for In-Flight Use -- % of Respondents --

Not applicable Not at all likely Not very likely Neutral Somewhat likely Very likely

% Somewhat + 

Very Likely

43%

42%

40%

57%

32%

Figure 17

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. If Wi-Fi was available on a flight, and were available at a reasonable cost, how likely would you be to purchase access to it while 

traveling in each of the following ways? Would you say very likely, somewhat likely, neither likely nor unlikely, not very likely or not 

at all likely?
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 23 

Length and purpose of flight aside, “reasonably priced” in-flight Wi-Fi generally means less than $10.00 to 

a majority of passengers. For personal flights, 60% of passengers would be willing to pay up to $9.99 for 

in-flight Wi-Fi, while 53% of passengers would be willing to pay the same for business flights. Notably, 

passengers seem to justify higher Wi-Fi prices for longer flights and for business purposes. 

Again, passengers ages 25-54 are most willing to pay for in-flight Wi-Fi access no matter the length of 

flight or for what purpose it serves. 

Interest in Expanded PED Usage and Ability to Make Cell Phone Calls on Aircraft

Four in ten (43%) passengers indicate they would like to be able to use PEDs during all phases of their 

flights, including during take-off and landing. Not surprisingly, passengers over the age of 55 are less 

likely to be interested than are those ages 25-44.

Yes

43%

No

53%

Don't know

4%

Interest in Being Able to Use Personal Electronic Devices 

During All Phases of a Flight -- % of Respondents --

Figure 18

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Would you like to be able to use your personal electronic devices during all phases of a flight, including take-off and landing? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 24 

When asked which activities, if any, should be restricted during flights, six in ten (61%) said making cell 

phone calls. Three in ten would like alcoholic drinks (29%) and connecting to the Internet (28%) to also be 

restricted. One quarter (27%) of passengers don’t believe any of the listed activities should be restricted. 

Of interest, passengers ages 25-34 are more likely than those 45-54 to think connecting to the Internet 

while in-flight should be restricted.

1%

27%

2%

3%

28%

29%

61%

Don't know

None of these

Other

Eating

Connecting to the Internet

Alcoholic drinks

Making cell phone calls

Activities That Should be Restricted During Flights -- % of Respondents --

Figure 19

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. Which activities, if any, do you think should be restricted during flights?

 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 25 

When specifically asked how they feel about the possibility of passengers being able to make phone calls 

during flights, feelings were generally mixed. With 51% expressing negative feelings and 47% expressing 

positive feelings, there was no strong majority either way.

Notably, significantly more female passengers believe in-flight cell phone calls would be annoying or 

distracting when compared to male passengers. 

Feelings About Passengers Being Allowed to Make Cell Phone 

Calls During Flights

-- Mentions of 5% or More --

% of 

Respondents

Negative (net) 51%

 Opposed / Don’t want that / Not a good idea 16%

 Too noisy / Too much talking 16%

 Could be annoying / Distracting 13%

Positive (net) 47%

 No problem / That’s fine / Okay 18%

 As long as it’s safe / Doesn’t interfere with plane operation or communication 7%

Neutral (net) 6%

 Neutral / Don’t care / Doesn’t matter 5%

Figure 20

Base=U.S. adults who have taken any flights in the past 12 months (n=375)

Q. How would you feel about the possibility of passengers being able to make cell phone calls during flight? 
Portable Electronic Devices on Aircraft

 © 2013 Airline Passenger Experience Association (APEX) and Consumer Electronics Association (CEA®). All rights reserved. 26 

Conclusions

 PEDs have become an integral part of our mobile society and the majority of U.S. adult airline 

passengers are bringing PEDs onto aircraft while traveling. 

 Not only do they bring PEDs with them while traveling, airline passengers and their travel 

companions use them from the time they board until they de-plane, often for entertainment 

purposes, but also for work-related activities.

 Many passengers feel it is important to be able to use PEDs when flying for both business and 

personal reasons, although less so for business travelers, suggesting that PED usage for 

entertainment purposes is more important than usage for work-related purposes.

 Importance of actually being able to connect their PEDs to the Internet is considerably lower than 

the importance of having the devices with them while traveling, further supporting the notion that 

PED usage for entertainment purposes is more important than usage for work-related purposes. 

 While the majority of passengers feel clear and proper instructions regarding the allowed usage 

of PEDs are given prior to take-off, the data show this is not always the case. Passengers are not

always turning their devices completely off when instructed to do so – some are instead putting 

them in airplane mode, while others choose to do nothing. 

 Almost one third of passengers report they have accidently left a PED turned on during a flight. 

Smartphones, the most common PEDs carried onto planes with passengers, are also the most 

common PED accidently left turned on. 

 Concern over the potential for interference from PEDs powered on is highest during both take-off 

and landing. Passenger concern is not nearly as high for devices powered on while in-flight or for 

devices left in airplane mode. 

 Passengers express interest in having in-flight Wi-Fi available to them and are more likely to 

purchase it on longer flights. 

 Passengers also indicate they would like to be able to use PEDs during all phases of flight, 

including take-off and landing. 

 While airline passengers express interest in expansion of PED use on aircraft, a majority believe 

that making cell phone calls should be restricted during flights, mainly due to the potential 

distraction it could create for other passengers. 
Comparison Summary: 

Portable Electronic Devices on Aircraft 

2003 vs 2013

April 2013
Comparison Summary: Portable Electronic Devices on Aircraft 2003 vs 2013

 © 2013 Consumer Electronics Association (CEA®). All rights reserved. research.ce.org 0 

Comparison Summary: 

Portable Electronic Devices on Aircraft 2003 vs 2013 

 Over the past decade, more airline passengers report carrying at least one portable 

electronic device (PED) with them while traveling by plane. In 2003, 76% of passengers said 

they brought at least one PED with them while traveling by plane. In 2013, that number rose by 

18 percentage points to 94% of airline passengers.

 Additionally, more passengers are carrying their PEDs with them onto the plane, as 

opposed to packing them in their checked luggage. In 2003, 23% of passengers traveling 

with PEDs packed at least one device in their checked bag(s) and 70% carried at least one 

device onboard the plane. In 2013, the percent of PED-carrying passengers packing devices in 

their checked luggage decreased slightly to 17%, while the percent carrying devices with them 

onboard increased considerably to 99%.

 As times have changed, so too have the devices passengers carry with them while 

traveling by air. Cell phones (55%), calculators (22%), laptop computers (21%), CD/DVD 

players (20%) and camcorders (14%) were the top five PEDs brought with travelers as carry-on 

items in 2003. Ten years later, in a highly connected and mobile society, portable computing 

devices top the list with smartphones being the number one PED carry-on (63%), followed by 

notebook or laptop computers (45%), basic cell phones (non-smartphone) (31%), portable digital 

audio or MP3 players (28%) and tablet computers (27%).

 With more passengers bringing PEDs with them onboard aircraft, usage of these devices 

while in-flight has increased as well. In 2003, only four in ten (40%) passengers used PEDs 

while in-flight (specific flight phases not specified). By 2013, however, usage increased to 69% 

during the flight and 85% while on the ground, either prior to take-off or after landing1

. 

o Among those who carried PEDs onto the plane with them in 2003, the most 

commonly used device in-flight was the CD/DVD player (17%). This was followed by 

laptop computers (15%), calculators (13%), cell phones (8%) and PDAs or handheld 

computers (8%). In 2013, all-in-one mobile devices appear to have taken over with 

smartphones (28%) topping the list of PEDs used while in-flight. Notebook or laptop 

computers (25%) closely follow, along with tablet computers (23%), portable digital 

audio or MP3 players (23%) and e-Readers (13%) rounding out the top five.

 Despite the fact that more passengers are bringing PEDs on board their flights, the 

incidence of devices accidently being left on during the times they should be powered 

completely down has remained stable over the past decade. In 2003, 29% of travelers who 

owned a cell phone or wireless pager reported they had accidently left the device turned on 

during a flight. Comparatively, in 2013, 30% of passengers reported they had accidently left a 

PED (not limited specifically to cell phones or wireless pagers) turned on while in-flight2. 

 The percent of passengers who feel clear and proper instructions are given regarding the 

use of PEDs onboard an aircraft has increased slightly over the past 10 years. In 2003, 

90% of passengers felt instructions given by flight crews were clear and proper. By 2013 that 

percentage increased to 94%, suggesting airlines continue to do a good job both communicating 
Comparison Summary: Portable Electronic Devices on Aircraft 2003 vs 2013

 © 2013 Consumer Electronics Association (CEA®). All rights reserved. research.ce.org 1 

what is and what is not allowed during the various phases of a flight and in adapting to everchanging mobile and wireless technologies. 

 Airline passengers are less concerned about the potential for interference with aircraft 

systems caused by PEDs than they were a decade ago. In 2003, more than half (56%) of 

airline passengers were concerned about the potential for PEDs to interfere with aircraft systems 

(non-specific as to the phase of the flight). In 2013, with most devices equipped with an ‘airplane 

mode’ feature (a feature not always available on PEDs in the early 2000’s) concern decreased to 

45% on average across all phases of a flight. Concern is highest for devices powered on during 

take-off (60%) and lowest for devices in ‘airplane mode’ while in-flight (26%) 3. 

 The perceived importance of being able to use PEDs on an aircraft has increased 

significantly over the past ten years, for both travel related to business and personal 

purposes. In 2003, three in ten passengers felt it was important to be able to use PEDs on 

airplanes for business (31%) and for personal reasons (28%). By 2013, those percentages rose 

considerably to 43% for business travel and 61% for personal travel.

 Interest in connecting to Wi-Fi in-flight has increased significantly over the past decade. 

Only one-third (34%) of passengers expressed interest in in-flight Wi-Fi in 2003. As connectivity 

has gained in importance and the in-flight Wi-Fi market has become more competitive, interest 

has grown to 57% in 2013 4.

 Passengers are more likely to pay for in-flight Wi-Fi services in 2013 than they were in the 

past. Nearly one quarter (23%) of passengers said they would be likely to pay for access to an 

in-flight wireless network in 2003. In 2013, regardless of purpose or length of flight, 43% of 

passengers (on average) say they are likely to purchase in-flight Wi-Fi. These passengers are 

most likely to pay for service on longer flights (over 3 hours) (57%) and least likely to purchase on

flights less than three hours long (32%). The purpose of the trip (e.g. business, personal or both) 

does not make much of a difference in likelihood to purchase, as approximately four in ten would 

purchase for any of said travel purposes5. 
Comparison Summary: Portable Electronic Devices on Aircraft 2003 vs 2013

 © 2013 Consumer Electronics Association (CEA®). All rights reserved. research.ce.org 2 

Methodology 

The Consumer Electronics Association is a member of the Marketing Research Association (MRA) and 

adheres to the MRA’s Code of Marketing Research Standards. 

 

CEA is responsible for all content contained in this briefing. Any questions regarding the study should be 

directed to CEA Market Research staff at info@CE.org. 

Portable Electronic Devices on Aircraft (2013)

The Portable Electronic Devices on Aircraft (2013) study was designed and formulated jointly by the 

Consumer Electronics Association (CEA) ® and the Airline Passenger Experience Association (APEX). 

This study presents the findings of a telephone survey conducted among two national probability 

samples, which, when combined, consist of 1,629 adults, 815 men and 814 women 18 years of age and 

older, living in the continental United States. Interviewing for this CARAVAN® Survey was completed on 

December 14-18, 2012. 1,093 interviews were from the landline sample and 536 interviews from the cell 

phone sample. 

 

The margin of sampling error at 95% confidence for aggregate results is +/- 2.43%. Sampling error is 

larger for subgroups of the data. As with any survey, sampling error is only one source of possible error. 

While non-sampling error cannot be accurately calculated, precautionary steps were taken in all phases 

of the survey design, collection and processing of the data to minimize its influence. 

 

During the fielding of this study, Consumer Electronics Association (CEA) ® and the Airline Passenger 

Experience Association (APEX) employed the services of Opinion Research Corporation (ORC) to 

conduct telephone interviewing. The telephone interviewing employed industry standard random-digit 

dialing and computer assisted telephone interviewing (CATI). 

 

Sampling 

ORC's CARAVAN® landline-cell combined sample is a dual frame sampling design. This means that the 

sample is drawn from two independent non-overlapping sample frames—one for landlines and one for 

cell phones. 

 

Land Line Sample 

ORC’s Random Digit Dial (RDD) telephone sample is generated using a list-assisted methodology. 

 

Cell Phone sample 

The MSG Cellular RDD database is constructed quarterly utilizing Telecordia’s LERG product. 

As is common practice in survey research, the data was weighted to reflect the known demographics of 

the population under study. In this survey, weights were applied to cases based on gender, age, race and 

geographic region. As a result, this data can be generalized to the entire U.S. adult population. 

The bases shown on all charts and tables are weighted bases. All percentages in the text, charts and 

tables included in this report are also based on weighted data. 

 

Portable Electronic Devices on Aircraft (2003) 

The Portable Electronic Devices on Aircraft (2003) study described herein was designed and formulated 

by eBrain Market Research (a division of CEA Market Research). The quantitative study was 

administered via telephone interview to a random national sample of 1,009 U.S. adults during September 

2003. The telephone interviewing employed industry standard random-digit dialing (RDD) and computer 

assisted telephone interviewing (CATI). Raw data from the completed study was aggregated by eBrain 

Market Research (a division of CEA Market Research). 
Comparison Summary: Portable Electronic Devices on Aircraft 2003 vs 2013

 © 2013 Consumer Electronics Association (CEA®). All rights reserved. research.ce.org 3 

Appendix 

Changes in the survey questions between 2003 and 2013 

1 2003: Q. Which electronics product did you use DURING a flight? 

2013: Q. And which of those portable electronic devices have you personally USED while on the 

 airplane...A.) during the flight B.) prior to take off or after landing 

2 2003: Q. Have you ever accidentally left your cell phone or wireless pager TURNED ON during 

a flight, perhaps by accident, either in your carry-on bag or pocket, or in your checked luggage? 

2013: Q. Have you ever accidentally left any of your portable electronic devices TURNED ON 

during a flight? 

3 2003: Q. How concerned are you about the potential for portable electronic devices to interfere 

with aircraft communication and navigation equipment? 

2013: Q. How concerned are you about the potential for portable electronics devices to interfere 

with aircraft communication and navigation equipment if they are each of the following? Would 

you say extremely concerned, somewhat concerned, neutral, not very concerned or not at all 

 concerned? 

4 2003: Q. How interested or not interested are you in being able to do each of the following while 

traveling on an airplane? C.) Connect to the Internet while in-flight using your own laptop 

computer through a wireless network on the airplane 

2013: Q. As you may or may not know, some airlines are beginning to offer in-flight Wi-Fi 

service. How interested are you in in-flight Wi-Fi services offered by a commercial airline, such 

as American, Delta or United? Would you say... 

5 2003: Q. If airplanes had wireless networks with Internet access, how likely would you be to buy 

the equipment you would need to use and connect to the wireless network? 

2013: Q. If Wi-Fi was available on a flight, and were available at a reasonable cost, how likely 

would you be to purchase access to it while traveling in each of the following ways? Would you 

say very likely, somewhat likely, neither likely nor unlikely, not very likely or not at all likely? 

A.) For business purposes 

B.) For personal purposes 

C.) For combined business and personal purposes 

D.) Flight less than 3 hours 

E.) Flight over 3 hours 
Delta Customer Survey Data

In support of the PED ARC efforts, Delta surveyed 1462 customers in October 2012 over the 

issue of expanded PED usage on flights. Our customers responded as follows:

o When asked to pick which device they would like to use the most below 10,000 feet, cell 

phone is the top choice followed closely by tablet computer. 

o Reading e-books, text messaging, listening to music, watching movies and playing games

are the top activities that customers would like to do below 10,000 feet

Note: Of the activities available on today’s smart phones, making cellular calls is only 

the 6th priority

o Most customers feel that being able to use electronic devices below 10,000 feet would 

have a positive impact on the onboard experience

o The ability to make phone calls is seen to have a negative impact on the onboard 

experience for 64% of customers; however, 36% of customers believe it would be 

positive indicating that phone calls in flight can be polarizing.

Impact on Onboard Experience if allowed to use PED’s 

Below 10,000 Feet

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

Very Positive

Somewhat Positive

Somewhat Negative

Very Negative
A Report from the PED ARC to the FAA

Appendix I: PED Interference Data Page I-1 

APPENDIX I:		 PED INTERFERENCE DATA		

Appendix I includes PED interference data reviewed by the PED ARC during its deliberations. 

The following information was compiled and prepared for publication by the member 

(organization) listed. 

• Delta Air Lines, Interference Event Data for PED ARC (January 1, 2010 to August 31, 

2012) 

• National Aeronautics and Space Administration, Passenger Electronic Device (PED) 

Related Incidents Special Request – Secondary Analysis, Search Request No. 7115 (April 

10, 2013) (presented to PED ARC by M. Schopp) 

Note: The FAA presented Service Difficulty Report (SDR) data, which is summarized in the 

safety risk analysis included in Appendix F of this report. 
A Report from the PED ARC to the FAA

Appendix I: PED Interference Data Page I-2 

(intentionally left blank) 
INTERFERENCE EVENT DATA FOR PED ARC

(Jan 1, 2010 to Aug 31, 2012)

Delta Airlines provides a summary of all reported equipment interference events from January 1, 

2010 to August 31, 2012. Any pilot or mechanic report that mentioned interference to the airline 

for any reason (mechanical, human factors or other cause) is included:

Summary:

• Delta flew 2.3 million flights during the period Jan 1, 2010 to Aug 31, 2012 

• Data Collected via Pilot reports and Aircraft Maintenance Defect Logs

– 3 Pilot Reports mentioned possibility of PED Interference, but none could be 

confirmed

– 24 Maintenance Defect Logs mentioned possibility of Unknown Interference 

(Radar 1, ILS Locator 1, Radio/Comm/Intercom 2)

• Of the 27 events recorded: 

– 6 events were explained by a positive mechanical finding other than PED 

interference

– 21 events remain 

• 2 events were associated with flying through weather/clouds

• 1 event was reported to have been due to ACARS interference 

• 2 events were caused by a stuck open microphone

• 16 remaining events were not confirmed, system worked fine on the 

ground
Aviation Safety Reporting System 

P.O. Box 189 | Moffett Field, CA | 94035-0189 

Search Request No. 7115 

Passenger Electronic Device 

(PED) Related Incidents

Special Request – Secondary Analysis 

 April 10, 2013 
National Aeronautics and 

Space Administration 

Ames Research Center 

Moffett Field, CA 94035-1000 

TH: 262-7 

MEMORANDUM FOR: Recipients of Aviation Safety Reporting System Data 

SUBJECT: Data Derived from ASRS Reports 

The attached material is furnished pursuant to a request for data from the NASA Aviation Safety 

Reporting System (ASRS). Recipients of this material are reminded when evaluating these data 

of the following points. 

ASRS reports are submitted voluntarily. The existence in the ASRS database of reports 

concerning a specific topic cannot, therefore, be used to infer the prevalence of that problem 

within the National Airspace System. 

Information contained in reports submitted to ASRS may be amplified by further contact with 

the individual who submitted them, but the information provided by the reporter is not 

investigated further. Such information represents the perspective of the specific individual who is 

describing their experience and perception of a safety related event. 

After preliminary processing, all ASRS reports are de-identified and the identity of the individual 

who submitted the report is permanently eliminated. All ASRS report processing systems are 

designed to protect identifying information submitted by reporters; including names, company 

affiliations, and specific times of incident occurrence. After a report has been de-identified, any 

verification of information submitted to ASRS would be limited. 

The National Aeronautics and Space Administration and its ASRS current contractor, Booz 

Allen Hamilton, specifically disclaim any responsibility for any interpretation which may be 

made by others of any material or data furnished by NASA in response to queries of the ASRS 

database and related materials. 

Linda J. Connell, Director 

NASA Aviation Safety Reporting System
CAVEAT REGARDING USE OF ASRS DATA 

Certain caveats apply to the use of ASRS data. All ASRS reports are voluntarily submitted, and 

thus cannot be considered a measured random sample of the full population of like events. For 

example, we receive several thousand altitude deviation reports each year. This number may 

comprise over half of all the altitude deviations that occur, or it may be just a small fraction of 

total occurrences. 

Moreover, not all pilots, controllers, mechanics, flight attendants, dispatchers or other 

participants in the aviation system are equally aware of the ASRS or may be equally willing to 

report. Thus, the data can reflect reporting biases. These biases, which are not fully known or 

measurable, may influence ASRS information. A safety problem such as near midair collisions 

(NMACs) may appear to be more highly concentrated in area “A” than area “B” simply because 

the airmen who operate in area “A” are more aware of the ASRS program and more inclined to 

report should an NMAC occur. Any type of subjective, voluntary reporting will have these 

limitations related to quantitative statistical analysis. 

One thing that can be known from ASRS data is that the number of reports received 

concerning specific event types represents the lower measure of the true number of such 

events that are occurring. For example, if ASRS receives 881 reports of track deviations in 

2010 (this number is purely hypothetical), then it can be known with some certainty that at 

least 881 such events have occurred in 2010. With these statistical limitations in mind, we 

believe that the real power of ASRS data is the qualitative information contained in report 

narratives. The pilots, controllers, and others who report tell us about aviation safety 

incidents and situations in detail – explaining what happened, and more importantly, why it 

happened. Using report narratives effectively requires an extra measure of study, but the 

knowledge derived is well worth the added effort. 
Chart 
Aviation Safety Reporting System

Passenger Electronic Device (PED) Related Incidents

January 1, 2002 – Present (n = 56 from ASRS Database)

Special Request – Secondary Analysis*

7

6

5

0

5

1

2

0 0

4

5

3 3

1

000 0

5

1

1

1

2

1 1 1 1

1

1 1

86420

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Year

Incidents

Passenger Handling/Management

Suspected or Confirmed PED EMI

PED Battery Issue, Smoke, Fire or Fumes

*Secondary Analysis involves an ASRS Expert Analysts codifying each record into specific safety topic categories. 
A Report from the PED ARC to the FAA

Appendix J: Passenger Non Compliance Data Page J-1 

APPENDIX J:		 PASSENGER NON‐COMPLIANCE DATA		

Appendix J includes passenger non-compliance data reviewed by the ARC during its 

deliberations. The information was compiled and prepared for publication by Airlines for 

America (A4A). 
A Report from the PED ARC to the FAA

Appendix J: Passenger Non Compliance Data Page J-2 

(intentionally left blank) 
Airlines for America COC Passenger Mi

0.08

0.09

0.11

0.05

0.22

0.32

0.09

0.00

0.00

0.06

Alcohol

Failure to Follow Crew Instructions-Seatbelt

Failure to Follow Crew Instructions-Carry-on Bag

Failure to Follow Crew Instructions-Pet

Failure to Follow Crew Instructions-PED

Failure to Follow Crew Instructions-Other

Threatening Behavior Level 4

Threatening Behavior Level 3

Threatening Behavior Level 2

Threatening Behavior Level 1

Smoking

0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 

Passenger Misconduct A4A Average 2011 - 2012

per 100M Revenue Passenger Miles 
Airlines for America COC Passenger Mi

Failure to Follow Crew 

Instructions-Seatbelt, 0.08, 

15%

Failure to Follow Crew 

Instructions-Carry-on Bag, 

0.09, 17%

Failure to Follow Crew 

Instructions-PED, 0.11, 20% Failure to Follow Crew 

Instructions-Pet, 0.05, 8%

Failure to Follow Crew 

Instructions-Other, 0.22, 40%

Passenger Misconduct - Failure to Follow Crewmember Instructio

A4A Average 2011-2012 per 100M Revenue Passenger Miles 
Airlines for America COC Passenger Mi

Definitions: 

Smoking:

Passenger appears intoxicated (boarding/during flight), drinking from own bottl

Smoking on aircraft, tampering with smoke detector

Failure to comply with crew instructions regarding carry-on baggage, portab

devices, seatbelt, pets, etc. (regulatory) 

As defined by Levels of Threat: 

Level 1: Passenger Disruption (Suspicious/Threatening) - Includes verbal or w

Level 2: Physical Contact (e.g., push, hit, slap, kick, grab)

Level 3: Life Threatening (e.g., weapon displayed, credible terrorist or bomb th

systems, credible hijacking

Level 4: Breach of Flight Deck

Alcohol: 

Failure to follow 

Crew Instructions 

(Regulatory):

Threatening 

Behavior:

Data collected from A4A member carriers is a voluntary process and the volume of reports ca

individual carrier reporting policies and practices. 
AReportfromthePEDARCtotheFAA

Appendix J: Passenger Non Compliance Data Page J-6

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix K: Index of Documents Reviewed Page K-1 

APPENDIX K:		 INDEX OF REFERENCE DOCUMENTS		

Appendix K includes an index of the guidance documents reviewed by the PED ARC and/or 

referenced in the PED ARC Final Report. 

FAA Guidance Documents

AC 20-158, The Certification of aircraft Electrical and Electronic Systems for Operation 

in the High-Intensity Radiated Fields (HIRF) Environment (7/30/07) 

AC 20-164, Designing and Demonstrating Aircraft Tolerance to Portable Electronic 

Devices (03/15/10) 

AC 23.1309-1E, System Safety Analysis and Assessment for Part 23 Airplanes 

(11/17/11) 

AC 25-17A, Transport Airplane Cabin Interiors Crashworthiness Handbook (05/18/09)

AC 25.562-1B, Dynamic Evaluation of Seat Restraint Systems and Occupant Protection 

on Transport Airplanes (01/10/06) 

AC 91-21.1B, Use of Portable Electronic Devices Aboard Aircraft (8/25/06) 

AC 120-76B, Guidelines for the Certification, Airworthiness, and Operational Use of 

Electronic Flight Bags (12/19/2011) 

AC 121-24C, Passenger Safety Information Briefing and Briefing Cards (07/23/03) 

AC 121-29B, Carry On Baggage (07/24/00) 

ANM-02-115-20, Corded Electrical Devices (08/30/02) 

FAA InFO 09018, Stowage of Items in Seat Pockets (11/12/09)

Order 8900.1, Flight Standards Information Management System 

RTCA Guidance Documents

RTCA DO-160G, Environmental Conditions and Test Procedures for Airborne 

Equipment (12/8/2010) 

RTCA DO-233, Portable Electronic Devices Carried Onboard Aircraft (8/20/1996) 

RTCA DO-294C, Guidance on Allowing Transmitting Portable Electronic Devices (TPEDS) on Aircraft (12/16/2008) 

RTCA DO-307 Change 1, Aircraft Design and Certification for Portable Electronic 

Device (PED) Tolerance (12/16/2008) 
A Report from the PED ARC to the FAA

Appendix K: Index of Documents Reviewed Page K-2 

(intentionally left blank) 
A Report from the PED ARC to the FAA

Appendix L: Glossary Page L-1 

APPENDIX L:		 GLOSSARY		

14 CFR Part 23: Airworthiness Standards: Normal, Utility, Acrobatic, and Commuter Category 

Airplanes 

14 CFR Part 25: Airworthiness Standards: Transport Category Airplanes 

14 CFR Part 91: General Operating and Flight Rules 

14 CFR Part 91K: Fractional Ownership Operations 

14 CFR Part 121: Operating Requirements: Domestic, Flag, and Supplemental Operations 

14 CFR Part 125: Certification and Operations: Airplanes Having a Seating Capacity of 20 or 

More Passengers or a Maximum Payload Capacity of 6,000 Pounds or More; and Rules 

Governing Persons on Board Such Aircraft 

14 CFR Part 135: Operating Requirements: Commuter and On Demand Operations and Rules 

Governing Persons on Board Such Aircraft 

Adverse Effect: HIRF effect that results in system failure, malfunction, or misleading 

information to a degree that is unacceptable for the specific aircraft function or system addressed 

in the HIRF regulations. A determination of whether a system or function is adversely affected 

should consider the HIRF effect in relation to the overall aircraft and its operation. (AC 20-158) 

Allowance Process: Process to allow the use of a PED on aircraft within an operator's fleet. 

(RTCA DO-294) 

Altitude: Altitude represents the environmental pressure relative to sea level to which the 

equipment is exposed during the tests. (RTCA DO-160) 

Approval: The act of formal sanction of an implementation by a certification authority (RTCA 

DO-294) 

Assessment: An evaluation based upon engineering judgment (from SAE ARP4761) (RTCA 

DO-294) 

Back Door Coupling: PED radio frequency transmissions that are radiated within the aircraft 

and received by aircraft electronic systems through their interconnecting wires or electronic 

equipment enclosures. (See generally, RTCA DO-294.) 

Cabin Crew: Employees whose duties are performed primarily in the airplane passenger cabin. 

(RTCA DO-294) 

Catastrophic: A failure condition preventing continued safe flight and landing. (Level A 

Systems) Classification of Systems in Terms of Airplane Level Assessment (from SAE ARP5413)

(RTCA DO-294) 
A Report from the PED ARC to the FAA

Appendix L: Glossary Page L-2 

Certification: The legal recognition that a product complies with the applicable requirements. 

Such certification comprises the activity of technically checking the product and the formal 

recognition on compliance with the applicable requirements by issue of a certificate, license, 

approval, or other documents as required by national laws and procedures (from SAE ARP 4761) 

(RTCA DO-294) 

Coupling: Process whereby electromagnetic energy is induced in a system by radiation produced 

by an RF source. (AC 20-158) 

Critical Phases of Flight: All ground operations involving taxi, takeoff and landing, and all 

other flight operations conducted below 10,000 feet except cruise flight. (121.542) 

Electronic Flight Bag (EFB): An electronic display system intended primarily for flight deck 

use that includes the hardware and software necessary to support an intended function. EFB 

devices can display a variety of aviation data or perform basic calculations (e.g., performance 

data, fuel calculations, etc.). In the past, some of these functions were traditionally accomplished 

using paper references or were based on data provided to the flightcrew by an airline’s flight 

dispatch function. The scope of the EFB functionality may include various other hosted 

databases and applications. Physical EFB displays may use various technologies, formats, and 

forms of communication. An EFB must be able to host Type A and/or Type B software 

applications. (AC 120-76B) 

Fly-by-Wire Controls: The airplane control surfaces are actuated by electric motors, digital 

computers, or fiber optic cables. This flight control system replaces the physical connection 

between pilot controls and the flight control surfaces with an electrical interface. (Airplane 

Flying Handbook, FAA-H-8083-3A, Chapter 5) 

Front Door Coupling: PED radio frequency emissions that are radiated within the aircraft, 

propagate through the aircraft windows and doors, and received by aircraft radio receivers 

through their antennas installed on the aircraft. (See generally, RTCA DO-294.) 

Hazardous/Severe – Major: Failure conditions reducing the capability of the aircraft or the 

ability of the crew to cope with adverse operating conditions to the extent that there would be 

(Level B Systems) a large reduction in safety margins or functional capabilities, physical distress 

or higher workload such that the crew could not be relied on to perform their tasks accurately or 

completely, or serious injury to a relatively small number of the occupants. Classification of 

Systems in Terms of Airplane Level Assessment (from SAE ARP5413) (RTCA DO-294)

High-Intensity Radiated Fields (HIRF): Electromagnetic environment that exists from the 

transmission of high power RF energy into free space. (AC 20-158) 

Major: Failure conditions that reduce the capability of the aircraft or the ability of the crew to 

cope with adverse operating conditions to the extent that there would be, for example, a 

significant increase in crew work load or in conditions impairing crew efficiency, or discomfort 

to occupants, possible including injuries. (Level C Systems) Classification of Systems in Terms 

of Airplane Level Assessment (from SAE ARP5413) (RTCA DO-294) 
A Report from the PED ARC to the FAA

Appendix L: Glossary Page L-3 

Minor: Failure conditions not significantly reducing aircraft safety, and which involve crew 

actions that are well within their capabilities. Minor failure conditions may include, for example, 

a slight reduction in safety margins or functional capabilities, a slight increase in crew workload, 

such as routine flight plan changes, or some inconvenience to occupants. (Level D Systems) 

Classification of Systems in Terms of Airplane Level Assessment (from SAE ARP5413) (RTCA 

DO-294) 

Phase of Flight – Arrival: Altitude within the sterile cockpit region and entering or crossing 

active runways. (RTCA DO-294, Table 2-1) 

Phase of Flight – Cruise: Flight altitude above the sterile cockpit region.(RTCA DO-294, 

Table 2-1) 

Phase of Flight – Departure: Entering active runway, take-off and climb out. Altitude within 

the sterile cockpit region. (RTCA DO-294, Table 2-1) 

Phase of Flight – Park/Gate: On-ground, aircraft stationary/parked. (RTCA DO-294, 

Table 2-1) 

Phase of Flight – Taxi-In: Taxiing between active runway and Park/Gate position. (RTCA DO294, Table 2-1) 

Phase of Flight – Taxi-Out: Taxiing between Park/Gate position and active runway. (RTCA 

DO-294, Table 2-1)

Spurious Emission: Emission on a frequency or frequencies which are outside the necessary 

bandwidth and the level of which may be reduced without affecting the corresponding 

transmission of information. Spurious emissions include harmonic emission, parasitic emissions, 

intermodulation products, and frequency conversion products, but exclude out-of-band emission. 

(RTCA DO-294) 

Sterile Cockpit: Rules in CFR 121.542 a, b, and c and CFR 135.100 a, b, and c discussion 

critical phases of flight operations are known as "Sterile Cockpit" rules. The rules list the 

altitude structure during departure and arrival where pilots must not be subject to undue 

distraction. The precise structure is determined by each operator and its oversight FAA office 

and generally includes operations below 10,000 feet except for cruise flight segments. (RTCA 

DO-294) 

Title 14 of the Code of Federal Regulations (14 CFR): Aeronautics and Space 

Title 47 of the Code of Federal Regulations (47 CFR): Telecommunications 

   
A Report from the PED ARC to the FAA

Appendix L: Glossary Page L-4 

(intentionally left blank)