Basically, no one is riding in the luggage hold if something suddenly starts smoking or starts a fire. By the time it was noticed, it would already be out of control at 60,000 feet, and there isn’t anywhere to run, and it’s a long way down.
In the cabin, there is a good chance that someone might notice something if one starts smoking or catches fire. There is a chance to react to it and isolate the battery fire. Plus a battery will usually stop working before it ever catches fire, so the owner might put the device away which may help take strain off the battery.
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