Flying Paperless Airplanes - Susan Parson
Okay, I admit it: I love gadgets, especially gizmos that let me
dispense with paper. Address book? That’s in the iPhone, which is
also well-stocked with a variety of handy aviation apps. Latest
version of a draft magazine article? That would be on the thumb
drive—but also accessible via a newly-acquired app that lets me put
files in one place and read them on any device with an Internet
connection. Weather info? The stack of dot-matrix printer paper I
used to lug around has long since been supplanted by datalink
weather acquired through a collection of handheld and panel mounted
devices. In my increasingly paperless world, the recent arrival of
updated paper instrument approach procedure (IAP) charts is
admittedly something of an anomaly. I do like the “security
blanket” aspect of those neatly folded paper charts, possibly
because I have personally seen how one mistaken button-push can
lead to instant and simultaneous amnesia for two GPS moving-map
navigators. Paper prevailed on that occasion. Still, the lure of
lightening my flight-bag load and dispensing with the clutter of a
papered airplane is strong. Envy of a pilot pal’s e-chart setup was
the final push I needed to do some basic research into the concept
of the Electronic Flight Bag (EFB). Here’s what I learned. There’s
a Doc for That Like airplanes themselves, EFBs come in a variety of
forms, capabilities, and restrictions. The FAA defines those forms,
capabilities, and restrictions—plus the term itself—in Advisory
Circular (AC) 120-76A, Guidelines for the Certification,
Airworthiness, and Operational Approval of Electronic Flight Bag
Computing Devices. It can be found at:
www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/23222.
Let’s get one important point on the table right away: As stated in
the opening paragraph of AC 120-76A, the guidance material in this
AC applies to the usual collection of commercial operators in Title
14 Code of Federal Regulations (14 CFR) part 121, 125, 129, or 135
operations. For 14 CFR part 91, it applies to large and
turbine-powered multi-engine aircraft operating under 14 CFR part
91, subpart F (which covers fractional ownership), but only if the
operating regulations require specific functionality and/or
equipage under 14 CFR section 91.503 for Flying equipment and
operating information. Other part 91 operations—including those of
us who fly light general aviation aircraft for business or
pleasure—do not require any specific authorization for EFB
operations, as long as the EFB does not replace any system or
equipment required by the regulations. Yet, even if the EFB
conditions and restrictions outlined in the AC don’t apply to the
kind of flying you currently do, it is still useful to know how the
FAA defines and classifies these devices. The ABCs of EFBs Advisory
Circular 120-76A defines the term EFB as: An electronic display
system intended primarily for cockpit/flight deck or cabin use. EFB
devices can display a variety of aviation data or perform basic
calculations (e.g., performance data, fuel calculations, etc.). The
scope of EFB system functionality may include various hosted
databases and applications. Physical EFB displays may use various
technologies, formats, and forms of communication. These devices
are sometimes referred to as auxiliary performance computers (APC)
or laptop auxiliary performance computers (LAPC). The FAA
categorizes EFBs in three classes. Class 1 and Class 2 EFB systems
are both based on commercial off-the-shelf (COTS) systems and both
are considered to be personal electronic devices (PED). Also, both
are portable (not permanently installed in the aircraft). The
difference between Class 1 and Class 2 is primarily derived from
how they are mounted in the aircraft and what must be approved. A
Class 1 system is not attached to an aircraft mounting device,
aircraft primary power supply, or data connectivity. Class 1 EFB
systems can be used both on the ground and during flight, but must
be stowed for takeoff and landing. They are limited to providing
supplemental information and cannot replace any required system or
equipment. A Class 1 EFB may be connected to aircraft power through
a certified power source to operate the EFB and recharge its
batteries. A Class 1 EFB can display tabular data, such as
performance tables, checklists, and the pilot operating handbook
(POH). A Class 2 EFB system can be attached to a
structural-mounting bracket to ensure that it does not interfere
with other aircraft systems. Though considered a PED, the use of a
structural-mounting bracket made only for that device means that a
logbook entry is required to remove a Class 2 EFB from the
aircraft. A Class 2 system can be connected to aircraft power and
to a certified data connection in order to exchange data with
aircraft systems and make interactive performance calculations. In
addition, a Class 2 EFB can be used to compute weight–and-balance
information as well as takeoff and-landing V-speeds. It can also
provide flightcritical data, such as navigation charts. Since it is
not necessarily stowed for takeoff and landing, a pilot can also
use the Class 2 EFB to display departure, arrival, and approach
charts. Class 3 EFB systems, which are the most capable, require
approvals. A Class 3 EFB system is installed equipment that, with
exceptions for user-modifiable software used to host certain kinds
of applications, requires a Supplemental Type Certificate (STC) or
certification design approval as part of the aircraft equipment. It
is also subject to certification requirements that enable
additional applications and functions. Know When to Hold ’Em There
was a time when features such as moving maps, airport diagrams, and
datalink weather existed only on Class 3 EFBs. Today, however,
these functions (and many more) are available in Class 2 models
that are—as the COTS characterization would imply—widely available
commercial devices that anyone can buy. However, due to lack of
airworthiness approval to demonstrate reliability, the display of
“own-ship” position in flight on a Class 1 or Class 2 device is not
authorized where regulatory compliance is required. A unit with
current IAP charts can be characterized as a Class 1 EFB, if it is
not attached to the airplane, or as a Class 2 EFB, if it is mounted
in the panel. The question is: Can you legally use an EFB?
According to the guidance, 14 CFR part 121 and 135 operators must
obtain specific operational authorization to use them. For those in
part 91 operations, however, the FAA states that use of Class 1 and
2 EFBs to replace paper charts is at the pilot’s discretion. Know
When to Fold ’Em That’s good news, of course, but pilots of
paperless airplanes need to use that discretion wisely. Reasons for
caution include: - Devices not subject to FAA approval of
components or installation are not guaranteed to provide the kind
of reliability you expect from products that have successfully made
it through these processes. - Devices can fail, and they often fail
at inopportune moments. In the personal example mentioned earlier,
the pilot’s hand was jostled by turbulence and he accidentally
pressed the GPS data-card ejection button instead of the
flight-plan key he meant to activate in response to an amended ATC
clearance. The unit—and the secondary unit configured for
“cross-talk” with the primary navigator—immediately went into
reboot mode and “forgot” everything connected with the flight. -
The cables, cords, and antennas required for portable EFBs can
create more clutter—and, potentially, more hazardous clutter—than
the paper charts they are intended to replace. The bottom line: EFB
technology is available here and now, and proper use of any class
of EFB system can improve efficiency and safety while eliminating
considerable weight in paper. Sounds like I need to shop for my
next gadget. Susan Parson is a special assistant in FAA’s Flight
Standards Service. She is an active general aviation pilot and
flight instructor.
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