Flying without Paper Charts

I recently gave a presentation about flying RNAV procedures at the Northwest Aviation Conference. As usual, I asked how many pilots in the audience were using tablets like iPads in the cockpit. Most of the folks raised their hands. It’s astonishing how quickly the aviation community has adopted this technology.

Nevertheless, questions persist about the legality of “going paperless” in the cockpit, at least for typical GA pilots operating light aircraft under 14 CFR Part 91. Here are some key references to help you understand the rules and good operating practices.

The best background is in AC 91-78-Use of Class 1 or Class 2 Electronic Flight Bag (EFB), which explains:

This advisory circular (AC) provides aircraft owners, operators, and pilots operating aircraft under Title 14 of the Code of Federal Regulations (14 CFR) part 91, with information for removal of paper aeronautical charts and other documentation from the cockpit through the use of either portable or installed cockpit displays (electronic flight bags (EFB).

The AC also notes:

This AC is applicable to instrument flight rules (IFR) or visual flight rules (VFR), preflight, flight, and post flight operations conducted under part 91, unless prohibited by a specific section of 14 CFR chapter I.

And it explains:

EFB systems may be used in conjunction with, or to replace, some of the paper reference material that pilots typically carry in the cockpit. EFBs can electronically store and retrieve information required for flight operations, such as the POH and supplements, minimum equipment lists, weight and balance calculations, aeronautical charts and terminal procedures…The in-flight use of an EFB/ECD in lieu of paper reference material is the decision of the aircraft operator and the pilot in command. Any Type A or Type B EFB application, as defined in [AC 120-76] may be substituted for the paper equivalent. It requires no formal operational approval as long as the guidelines of this AC are followed.

You can find further guidance on the FAA website here. And Sporty’s has a good overview of the topic here. For information about using iPads and the like on practical tests, see this item at AOPA.

If you fly IFR using an approved GPS navigation system, you can find additional guidance (and common sense advice) in documents such as the Operational Suitability Report for the Garmin GTN series navigators, published by the FAA in 2011, and available in the FSIMS system, here.

The following Type B applications were evaluated under this report:

(1) Chart capability is limited to Approach Charts, Standard Terminal Arrival Routes, Departure Procedures and Airport Diagrams. Access to the chart information is accomplished by touching the chart symbol on the screen home page. Scaling is accomplished by touching the plus or minus signs on the screen. Chart information is in standard chart layout, oriented in portrait view. It is possible to overlay an approach chart on the navigation display. Navigation Display Approach Chart overlays however, are always oriented so that North on the chart is at the top of the display. Caution should be taken when using this feature, as it can be confusing in some circumstances.

(2) En route charts are not available to view in the GTN 7XX series of units. Airways and associated navigation aids and intersection names are displayed on the navigation display but not in chart format. Because en route chart view is not available, operators will be required to have immediately accessible a suitable approved aeronautical information source of en route charts.

A typical installation includes a GTN 7XX paired with a GTN6XX. Since the GTN6XX series of navigator does not have chart capability a second GTN7XX with charts and an independent power source may be installed to provide the necessary backup. Another method of redundancy could be for the operator to carry an approved stand alone Class I, or Class II EFB device onboard the aircraft. Otherwise, a set of paper charts is required to provide chart redundancy.

In the case of a single unit installation, paper charts (including approach, departure and arrival procedure, airport diagram and en route charts) must be onboard the aircraft or an approved stand alone Class I, or Class II (with a suitable approved source of aeronautical data) device may be substituted for paper charts.

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Paperless in the Cockpit

Most pilots who regularly fly IFR or travel beyond the local area are now using electronic charts and apps like ForeFlight, WingX, Garmin Pilot, or FltPlan to plan trips and navigate while in the air. In addition to charts, these apps include information about airports (from the Chart Supplement, formerly the A/FD), weather, fuel prices, and other details.

iPad Pilot News at Sporty’s is a good source of information about the latest hardware and software for use in the cockpit.

As I noted in Downloading Avionics Manuals, you can also copy handbooks for avionics and other key aircraft references to tablets and phones. But many pilots aren’t sure if those electronic references are legal substitutes for paper copies of required documents.

FAA offers guidance for Part 91 operators in AC 91-78 Use of Class 1 or Class 2 Electronic Flight Bag (EFB):

1. PURPOSE. This advisory circular (AC) provides aircraft owners, operators, and pilots operating aircraft under Title 14 of the Code of Federal Regulations (14 CFR) part 91, with information for removal of paper aeronautical charts and other documentation from the cockpit through the use of either portable or installed cockpit displays (electronic flight bags (EFB)).

2. APPLICABILITY. This AC is applicable to instrument flight rules (IFR) or visual flight rules (VFR), preflight, flight, and post flight operations conducted under part 91, unless prohibited by a specific section of 14 CFR chapter I.

The advisory circular notes that use of electronic documents can extend beyond charts:

Electronic Flight Bag (EFB). An electronic display system intended primarily for cockpit or cabin use. EFB devices can display a variety of aviation data (e.g., checklists, navigation charts, pilot’s operating handbook (POH)) or perform basic calculations (e.g., performance data, fuel calculations)….Operators have long recognized the benefits of using portable electronic devices (PED), such as commercially available portable computers, to perform a variety of functions traditionally accomplished using paper references. EFB systems may be used in conjunction with, or to replace, some of the paper reference material that pilots typically carry in the cockpit. EFBs can electronically store and retrieve information required for flight operations, such as the POH and supplements, minimum equipment lists, weight and balance calculations, aeronautical charts and terminal procedures. EFB systems are being developed to support functions during all phases of flight operations.

And the AC specifically notes that:

6. REMOVAL OF PAPER FROM THE COCKPIT FOR OPERATIONS UNDER PART 91.

a. EFBs/ECDs can be used during all phases of flight operations in lieu of paper reference material when the information displayed meets the following criteria:

(1) The components or systems onboard the aircraft which display precomposed or interactive information are the functional equivalent of the paper reference material.

(2) The interactive or precomposed information being used for navigation or performance planning is current, up-to-date, and valid…

b. The in-flight use of an EFB/ECD in lieu of paper reference material is the decision of the aircraft operator and the pilot in command. Any Type A or Type B EFB application, as defined in AC 120-76 may be substituted for the paper equivalent. It requires no formal operational approval as long as the guidelines of this AC are followed.

c. It is suggested that a secondary or back up source of aeronautical information necessary for the flight be available to the pilot in the aircraft. The secondary or backup information may be either traditional paper-based material or displayed electronically.

The FAA also points out several common-sense considerations to keep in mind when going paperless, and it outlines a process for testing and training to ensure that the use of electronic handbooks won’t interfere with the safe, efficient operation of the aircraft:

a. The operator should carry out an assessment of the human-machine interface and aspects governing Crew Resource Management when using the EFB. General considerations for the assessment includes workload, integration of the EFB into the cockpit, display and lighting issues, system shutdown, and system failures…Attention must be given to the physical EFB. Some items to consider are placement issues such as stowage during takeoff or landing, and the operation of an unsecured EFB. Use of the controls and input devices may be easy on the ground, but demanding in flight.

(1) Training should include preflight checks of the system, the use of each operational function on the EFB, the conditions (including phases of flight) under which the EFB should not be used, and procedures for cross-checking data entry and computed information.

b. Operators transitioning to a paperless cockpit should undergo an evaluation period during which the operator should carry paper backups of the material on the EFB. The backup should be readily available to the crew. During this period the operator should validate that the EFB is as available and reliable as the paper-based system being replaced.

It’s not explicitly clear from this advisory circular if an electronic copy of the aircraft flight manual (AFM), keyed to a specific aircraft serial number/registration number, is acceptable. But the AC does seem to allow use of PDF copies of avionics handbooks, weight-and-balance data, and STC supplements. For an example of an FAA legal interpretation that addresses some of these issues, see the Sweet letter (2011).