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The EFB Wait-Loss Program:
They’re more than weight-savers - EFBs save time.

Take delivery of a new business aircraft this year and the odds favor that the package includes a couple of bonuses: The unparalleled gratitude of the successful sales team…and an Electronic Flight Bag loaded with the digitized copies of all the salient documents (save for the pieces of hard copy still required - namely the airworthiness certificate and aircraft registration).

Whether your EFB solution meshes with the governing Federal Air Regulations and others depends to some extent on the operational rule under which you generally fly the aircraft. But the increasingly ubiquitous iPad is at the head of the pack when it comes to winning approval for use in operations covered by commercial rules – FAR121- FAR 125- even FAR 91 Sub-part K for fractional programs.

EFBs deliver benefits on several levels – increasingly important among them is the time saved with the reduced trouble and expedited ability to communicate between manufacturers and operators – a channel dating back decades. But before tackling the changeover- it’s worth assessing operation plans to use an electronic device to its best potential.

There’s no sense reducing one set of problems while increasing another (like running afoul of the FARs or finding oneself aloft- lacking important documents- and wishing you were back on the ground… something the missing documents would help expedite).

THE GOOD- THE BETTER AND THE BAD…
The EFB- whether purpose-built- home-rolled- or adapted on an iPad- can in one device obviate the need for a portable GPS back-up navigator- an E6B flight computer- and that heavyweight vestige of aviation’s first century: paper manuals- company operational documents- aircraft-specific checklists and that signature accessory of the working aviator: the leather chart case.

Already growing in popularity as a purpose- made system of hardware and software- the advent of these tablet devices and EFB software was driving a fresh new wave of interest before Apple introduced its monumentally successful profit center known as the iPad.

The device and the way Apple works in advance with developers positioned the device to quickly become a pilots’ hottest new gadget. The pilot simply needs to acquire that iPad- buy and load the appropriate software and as quickly as the device loads and launches it becomes an EFB.

This fresh wave of iPad appeal washes beyond prior EFB solutions and attracted more pilots than had ever seemed drawn to the purpose-built- factory-created EFBs – even though most of those arrived ready to work- delivering charts- plates and procedures while also providing GPS-driven geo-referencing.

According to officials from Jeppesen- the company’s use of paper in 2010 – the year of the iPad debut – dropped to 1 billion pieces- down 75 percent from the 4 billion being used at the turn of the century. The paper use dropped again in 2011- but not as dramatically. And the company ascribes those two years of paper declines wholly to the embrace of electronic charting – predominantly driven by the iPad.

Advantages of the EFB also extend beyond reduction of paper usage. Better managing updates stands as one of the most-noted appeals. The serious aviator diligently (if not necessarily happily) tracks and files chart- plate and procedure updates as they come in – every 28 days- 13 times a year. One-click update management is one of the more significant gains of a well-executed EFB – beyond the paper reduction.

FAR 91 FIRST: WHAT IS LEGAL?
Commercial- whether chartered or scheduled airline- mostly develop and win approval of company Operational Specifications. FAA approval gives an operation’s OpSpec the legal equivalence of the FARs themselves. Under FAR Part 91 we lack such formalities. While equally strong company policies may set their own operating limits- under FAR Part 91 we’re free to be as liberal or conservative as we wish. That’s a lot of freedom- comparatively.

The requisite FARs tell us we need to be properly prepared for the trip we plan to take- to be familiar with the route or routes- the arrival airport and salient information on conditions and facilities between here and there. Technically- that means no requirement for charts or plates when flying under Visual Flight Rules (VFR) under Visual Meteorological Conditions (VMC).

Fly under Instrument Flight Rules (IFR) – even if conditions aren’t Instrument Meteorological Conditions (IMC) – and the charts and plates appropriate for the trip should be at your fingertips- digitally or pulp-based

Below 18-000 msl and under VFR rules we need carry nothing in the way of charts and approach plates- but we still need the Pilot Operating Handbook- a valid Weight-and- Balance document- and instructional manuals for sundry avionics equipment. To that role under FAR Part 91- we’re free to meet those needs as best we see fit – as long as the need is being met when that rare Ramp Check arrives.

The FAR Part 91 pilot can use an EFB- iPad or otherwise- to provide all the POH- Operating Manuals- Avionics Instructional Manuals- VFR and IFR charts- plates and procedures. In fact- all the basics of EFB use are found in an Advisory Circular- AC 91-78b- (which can be viewed at http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/list/AC%2091-78/$FILE/AC%2091_78.pdf).

Other issues- approvals and classifications are available in AC 120-76a (http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/b5de2a1cac2e1f7b86256ced00786888/$FILE/AC%20120-76A.pdf).

SEPARATE ISSUES:
EQUIPMENT & USE
The FAA Advisory Circular 120-76a referred to above provides the needed framework for defining and implementing EFB solutions while adhering to the applicable FARs- and is written primarily for aircraft operators flying under Part 121 or Part 135 rules- or anyone else with OpSpecs or MSpecs. Conversely- AC 120-76a does not directly apply to Part 91 (or Part 91 Sub-Part F) operators- except as a “best practices” document- or when the EFB is used to replace required equipment.

AC 120-76a separates EFB hardware into three Classes and EFB software into three Types; the AC also provides guidelines on maintenance and airworthiness requirements- on human factor considerations- and serves up guidance on the OpSpecs approval process and how it can be applied to the use of EFBs.

EFB HARDWARE CLASSES:
• Class 1 EFBs – A Portable Electronic Device (PED) that is usually stowed during critical phases of flight. Class 1 EFBs can connect to ship’s power and read-only data sources. Other than power and data connectivity- Class 1 EFBs are not subject to airworthiness requirements such as DO-160E- and can run Type A and Type B applications.
• Class 2 EFBs – Still considered a PED- Class 2 have all of the capabilities of a Class 1 EFB- but may be used during critical phases of flight using either an airworthy mounting device or knee board. Like Class 1 EFBs- Class 2 EFBs are typically Commercial Off-the-Shelf (COTS) systems modified for aircraft use or are designed specifically for EFB applications.
• Class 3 EFBs – These are essentially avionics systems subject to airworthiness and regulatory requirements such as DO- 160E hardware requirements and DO- 178A software requirements. They range from panel mounted Multi-function Displays (MFD) to custom integrated airworthy systems (such as those based on Paperless Cockpit’s FliteServ C3 platform).

AC 120-76A APPLICATION TYPES:
Type A Applications: Typically pre-composed- static versions of traditionally paper documents. Under AC 120-76a- Type A Applications:
• May be hosted on any of the hardware classes;
• Require Flight Standards District Office (FSDO)/PI approval for OpSpecs holders (i.e. Part 135- Part 121);
• Do not require an AIR design approval;
• Are not subject to RTCA DO-178B software requirements.

Type B Applications: Typically interactive applications that allow manipulation of the presentation- such as panning and zooming on a chart. Under AC 120-76a- Type B Applications:
• May be hosted on any of the hardware classes;
• Require FSDO/PI approval for OpSpecs holders;
• Require AEG evaluation for OpSpecs holders;
• Do not require an AIR design approval;
• Are not subject to RTCA DO-178B software requirements.

Type C Applications: These are avionics-grade applications subject to airworthiness requirements- including DO-178B Software Assurance- AEG evaluation and AIR design approval.

WORTH THE WEIGHT – AND THE WAIT
With the successful testing of them in catastrophic decompression events- the iPad won approval for use in Part 91 Sub-Part K fractional and Part 135 operations- with Part 121 use of Type A applications already available.

The question should be “what does my operation need- and how do I assure the legality?” after which you should ask what’s taking you so long to make the move. Flight crew- flight department managers and even maintenance crew have found the portable tablet a useful tool. And with cockpit applications expanding to include two-way communications between the iPad and aircraft systems- the utility of what started as an EFB candidate can hardly be considered at its peak.

So for all you Part 91 operators out there who hunger for a way out of paper charts- heavy chart bags and monthly updating chores- your options are available- multiple and - best of all - cheap and legal. Now…when will you make the switch?

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