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EFB Part 91 Best Practices

While electronic flight bags (EFBs) can be helpful tools, when they are used in flight operations without thoughtful planning and consideration, they can lead pilots into dangerous situations.

EFB use in Part 91 operations is not expressly regulated by the FAA. “Unlike Part 135 and 121 operators and Part 91(K) fractional program managers, Part 91 operators are not required to submit a formal EFB program to the FAA for approval or acceptance,” noted Brian Koester, CAM, NBAA’s director of flight operations and regulations. “Instead, Part 91 operators have considerable leeway in using EFBs. However, it’s important to use EFBs and associated software in a safe manner.”

Consider these best practices when implementing an EFB program or improving an existing EFB program.

Choose Equipment, Applications Carefully

Operators should consider factors that can cause interference or inaccurate location readings. While EFBs are widely used with minimal reported incidents of interference, it’s still important to look at these issues. Own-ship displays, for example, rely on very accurate readings as precise as +/- 25 meters. Also consider electromagnetic compatibility with your aircraft’s navigation and communications systems.

What GPS sensor are you going to use, and is that sensor compatible with your aircraft? Many aircraft have an electrically heated windshield, for example. Is the GPS sensor effective given the location of the EFB, or do you need an external antenna? And if an external antenna is needed to prevent interference and to ensure accurate readings, where will you place it?

What portable EFB device will you use, and how will you mount it? iPads are certainly a common choice, but they come in several flavors as well. Be sure the device you choose has enough data storage, a fast enough processor, and adequate battery life for your use. Make sure the device is readable in sunlight while also having the ability to dim for night operations.

Matt Simmonds, chief pilot of a Texas-based flight department, says different types of mounts or EFB sizes are appropriate for different aircraft. When mounting an EFB, consider a cooling mount or a location out of direct sunlight to prevent overheating. If you plan to use your EFB in your lap, there are a variety of kneeboard mounts and straps available to secure it.

Also try different apps to see what works best for your planned use. Consider apps not just for aeronautical charts and weather reporting, but also for distributing company manuals. Some apps support annotations and note taking with a stylus such as an Apple Pencil. It’s a great way to transition toward a completely paperless flight deck.

Be intentional about your equipment and application choices. Don’t just use the latest version of the iPad and the same apps as your hangar-mate’s operation. Investigate different options and choose what works for your operation.

Document EFB Policies and Procedures

Part 91 operators are not required by regulation to have written EFB policies and procedures, but documenting policies and procedures is certainly a best practice.

The latest “official” FAA guidance for Part 91 EFB operations is Advisory Circular (AC) 91-78, Use of Class 1 or Class 2 Electronic Flight Bag (EFB), which Jason Herman, chair of NBAA’s Domestic Operations Committee, notes was written before the iPad was even invented. Herman suggests Part 91 operators instead review AC 120-76D, Authorization for Use of Electronic Flight Bags.

“If you’re looking for a comprehensive best practice, look to AC 120-76D for guidance, but realize that this advisory circular is not technically applicable to Part 91 operators.”

Jason Herman Chair, NBAA’s Domestic Operations Committee

“If you’re looking for a comprehensive best practice, look to AC 120-76D for guidance, but realize that this advisory circular is not technically applicable to Part 91 operators,” said Herman.

Topics to consider when developing EFB SOPs include:

  • Who provides the devices – the company or the pilots? How do you handle devices for contract pilots?
  • If personal devices are used, how do you ensure those devices meet company standards?
  • How are company manuals updated on the devices – a “push” from a document management program, or a manual download process?
  • ow do pilots ensure current app revisions are being used?
  • What are appropriate uses of WiFi in flight (if equipped)?
  • What minimum battery level is required to begin a flight? How will batteries be charged? Are backup batteries required?
  • How many functional EFB devices are required per flight? What procedures are to be followed when a required device is inoperative?

A minimum of two identical devices should be on board if the devices are used for critical applications, including enroute and approach charts. However, it’s even better to have a primary EFB for each pilot and one backup EFB readily available. Pilots should ensure all devices have current application revisions and databases in case the backup device becomes the primary device.

In some cases, the airplane itself has onboard charts, providing a backup to portable EFBs. Crosschecking the currency of these charts against those of the EFB is an important step to ensure data integrity.

Another important question to answer is when should pilots update apps and operating software? An error in updating or a bug in an operating software could easily turn your device into a brick right before a big trip.

“To avoid 'bricking' your devices, consider implementing policies restricting device updates to a minimum of three or four hours before departure”

To avoid “bricking” your devices, consider implementing policies restricting device updates to a minimum of three or four hours before departure, or restrict updates to one EFB device per aircraft at a time until the update is complete, and the pilot tests needed applications to ensure safe use. If the malfunction is discovered in flight, it can leave crews without access to important information or diminish situational awareness.

Simmonds recommends verifying all apps are current and syncing all data at each navigation database update. “We provide a list of apps required to be on the iPad, but the company doesn’t have control of the devices, so it’s the pilot’s responsibility to ensure apps and databases are current,” he said.

Part 91 operators can implement a safe, efficient and effective EFB program by following a few simple best practices. Choose your EFB equipment with intention. Document and train your EFB policies and procedures. Review and update those policies and procedures regularly, then plan for future equipment updates.

Ensuring Consistent EFB Implementation

Implementing an EFB program will likely require changes to other documents in your operation. Review checklists, company operations manuals, SOPs and training materials to reflect your new EFB program.

All pilots should be trained in using your EFB program. Also consider training other aviation personnel involved in scheduling and dispatching if these individuals are involved in securing backup charts or distributing other vital information.

Continual review of the EFB manual is important. Are the documented policies and procedures reflected in actual operations, or are workarounds or different policies and procedures actually being used? If pilots are using different practices, are they better than the documented policies and procedures? Ensuring that the EFB program manual and other company documents are aligned with actual operating practices is particularly important, especially when onboarding new pilots and flight department personnel.

Work with all pilots in your organization to review policies and procedures. Use their feedback to improve the program. Frequent review of your EFB program will keep your program relevant and ensure the most effective and efficient policies and procedures are in place. Be sure to train pilots on any new or revised policies and procedures.

Play the Long Game

What does your EFB replacement schedule look like? Planning ahead can help you budget accurately and ensure you’re purchasing the right device for your operation.

Up to four years is a reasonable expectation for EFB life, depending on technology improvements during that period and overall usage, which can impact battery life. It’s important to ensure processors in devices can keep up with updates in applications. Matt Simmonds, chief pilot of a Texas-based flight department, says his organization replaces devices every two years, but the company keeps the old devices as backups.

Jason Herman, chair of NBAA’s Domestic Operations Committee, notes that frequent updates to commonly used applications can quickly outpace devices. “Nearly any time you order a new device, you’re likely to already be behind soon thereafter,” he said.

Herman also suggests testing a single device before upgrading the fleet to see if there’s a noticeable improvement worth the expense of updating the entire fleet.

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