July 24, 2012
NBAA’s Operations Service Group has reviewed the changes that the Federal Aviation Administration (FAA) recently made to the agency’s Advisory Circular (AC) on the use of electronic flight bags (EFBs) in flight operations, and has clarified the new provisions, which had confused many aircraft operators.
The most common question NBAA receives from pilots and flight department managers evaluating the use of tablet devices has to do with the extent to which FAA approval is required in order to use an iPad in the cockpit. With the rapid advance of EFB technology, the FAA has been working to create guidance that keeps pace with how pilots are using the devices. In 2011, the FAA began the process of revising AC 120-76 on EFB certification and operational use. NBAA submitted comments to the FAA during this process stressing the need for clarity and highlighting the importance of maintaining operator flexibility.
Existing guidance from the FAA in AC 91-78 explains that operators conducting flights under FAR Part 91 are allowed to use devices such as the iPad in place of paper aeronautical charts. However, during the revision of AC 120-76, the FAA created specific EFB testing and documentation requirements for operators flying large (over 12,500 lbs.) or multi-engine turbine-powered aircraft under Part 91F.
While the published AC 120-76B provides guidance specific to Part 91F operators, FAA authorization is not required for EFB use so long as the device does not replace any system or equipment required by regulation. However, the AC does explain that Part 91F operators should document their compliance with a number of items as they employ the use of EFBs. “Operators that are currently using, or plan to use, EFBs in the cockpit need to follow some transitional and operational record-keeping practices related to certain compliance and safety issues,” explains Peter Korns, NBAA Operations Service Group specialist.
For example, Part 91F operators are allowed to use an EFB in lieu of paper reference material without specific FAA approval, but the AC advises documenting how operators evaluated the EFB and determined its suitability as a paper replacement. The AC also suggests establishing a validation period during the paperless transition and ensuring the carriage of a backup source of aeronautical information, which can be paper-based or a secondary EFB.
In addition to these operational items, there are various testing requirements that the AC suggests Part 91F operators complete and document. Testing the EFB to ensure that it does not interfere with other electronic systems on board the aircraft is important. This electromagnetic interference (EMI) testing can be completed using a process outlined by the AC. With the increased focus on battery safety, the AC also advises that operators document a maintenance plan for lithium-ion batteries.
One area of significant confusion surrounds the requirements to conduct rapid decompression testing on EFBs that will be used in pressurized aircraft. The AC makes clear that decompression testing does not need to be completed on every single EFB, and obtaining documentation that testing was successfully completed on a representative device is adequate. Many of the vendors that provide software applications for devices such as the iPad are able to provide evidence of successful decompression testing.
Although AC 120-76B does not specifically apply to Part 91 operations (other than 91F and 91K), the guidance should still be consulted as a reference. For Part 135 and other certificated operators, formal approval is required for EFB use through the issuance of OpSpec A061.
With the publication of AC 120-76B, all Part 91 operators are still permitted to use EFBs without formal FAA approval, but Part 91F operators are advised to document compliance with a significant number of items.
“While advisory circulars are in fact advisory in nature, they do represent FAA’s view and, operators are strongly urged to follow the documentation and testing guidance to ensure the safe and effective use of this technology,” said Korns.
Even with the expanded FAA guidance, the pilot in command for Part 91 flights is still ultimately responsible for ensuring the safe and reliable use of an EFB.