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.

Use of IFR GPS on Conventional Approaches

FAA has published an update to the AIM, effective 26 May 2016, and it includes a big change if you have an IFR-approved GPS [i.e., a “suitable navigation system” as defined in AC 20-138 and AIM 1-2-3 (b).]

Now, if you fly a conventional approach based on a VOR or NDB (but not a localizer), you can fly the procedure entirely with the GPS, provided you can monitor (using a separate CDI or a bearing pointer) the VOR or NDB facility specified for the approach.

The new language is in section 1−2−3. Use of Suitable Area Navigation (RNAV) Systems on Conventional Procedures and Routes.

The summary of changes to this AIM update notes that:

This change allows for the use of a suitable RNAV system as a means to navigate on the final approach segment of an instrument approach procedure (IAP) based on a VOR, TACAN, or NDB signal. The underlying NAVAID must be operational and monitored for the final segment course alignment.

The new text in the AIM is in paragraph 5 of AIM 1-2-3:

5. Use of a suitable RNAV system as a means to navigate on the final approach segment of an instrument approach procedure based on a VOR, TACAN or NDB signal, is allowable. The underlying NAVAID must be operational and the NAVAID monitored for final segment course alignment.

This change is the result of a discussion at the Aeronautical Charting Forum in 2014.

Changes in AIM Effective 26 May 2016

FAA has published an update to the AIM, effective 26 May 2016, and it includes several important changes of interest to typical general-aviation pilots:

1−2−3. Use of Suitable Area Navigation (RNAV) Systems on Conventional Procedures
and Routes

This change allows for the use of a suitable RNAV system as a means to navigate on the final approach segment of an instrument approach procedure (IAP) based on a VOR, TACAN, or NDB signal. The underlying NAVAID must be operational and monitored for the final segment course alignment. [For more information about this item, see the detailed discussion here.]

3−2−3. Class B Airspace
This change adds an RNAV Receiver as an option for instrument flight rule (IFR) navigation requirement IAW 91.131 (c)(1).

3−2−6. Class E Airspace

This change updates the definition, vertical limits, and types of Class E airspace. The change more accurately reflects Class E airspace regulatory information in 14 CFR Part 71 and more clearly states that Class E arrival extensions have the same effective times as the airport surface area airspace….

4−3−22. Option Approach
This changes adds verbiage advising pilots to inform air traffic control (ATC) as soon as possible of any delay clearing the runway during their stop−and−go or full stop landing.

5−2−8. Instrument Departure Procedures (DP) − Obstacle Departure Procedures (ODP) and Standard Instrument Departures (SID)
This change adds language advising pilots what to expect when vectored or cleared to deviate off of an SID.

5−4−1. Standard Terminal Arrival (STAR) Procedures
This change adds language advising pilots what to expect when vectored or cleared to deviate off of a STAR. Pilots should consider the STAR cancelled. If the clearance included crossing restrictions, controllers will issue an altitude to maintain. It also adds language advising pilots when to be prepared to resume the procedure. Since all clearances on STARS will not include Descend Via clearances, the word “will” was replaced with “may.”

5−4−7. Instrument Approach Procedures
This change adds a note to provide guidance to pilots regarding what to expect when clearances are issued by ATC to altitudes below those published on IAPs.

Garmin GTN Avionics and RF Legs

The release of updated operating software for Garmin GTN-series avionics brings new capabilities to many typical general aviation pilots who fly under IFR. One of the new features is the ability to fly curved radius-to-fix (RF) legs on some instrument approaches.


Until recently, RF legs were published only on so-called RNP procedures with authorization required (AR) restrictions (for more information, see AIM 5−4−18: RNP AR Instrument Approach Procedures). But FAA has started publishing some approaches with RF legs (like the example above) that are not designated as RNP AR procedures. And, with some limitations, pilots who fly aircraft equipped with GTN-series avionics should be able to fly the RF legs used as transitions/feeder routes on those approaches. (Note that so far, these approaches don’t require RF capability–conventional transitions/feeder routes and/or radar vectors are also available.)

For more information about RF legs, see RNP Procedures and Typical Part 91 Pilots and Garmin Radius to Fix Leg Project Report here at BruceAir. For additional background on GPS navigation and RNP procedures, see also Updated AC 90-105A.

The revised STC for the GTN series (document 190-01007-A5) notes that:

GPS/SBAS TSO-C146c Class 3 Operation
…The Garmin GNSS navigation system complies with the equipment requirements of AC 90-105 and meets the equipment performance and functional requirements to conduct RNP terminal departure and arrival procedures and RNP approach procedures including procedures with RF legs subject to the limitations herein [emphasis added].

Sections 2.12 RF Legs and 2.13.1 RNP 1.0 RF Leg Types of the STC add the following information:

2.12 RF Legs
This STC does not grant operational approval for RF leg navigation for those operators requiring operational approval. Additional FAA approval may be required for those aircraft intending to use the GTN as a means to provide RNP 1 navigation in accordance with FAA Advisory Circular AC 90-105. [Note that per AC 90-105A, domestic Part 91 operations do not require additional approval–only Part 91 subpart K operations and commercial operations need LOAs or the equivalent FAA approval.]

The following limitations apply to procedures with RF legs:

  • Aircraft is limited to 180 KIAS while on the RF leg
  • RF legs are limited to RNP 1 procedures. RNP AR and RNP <1 are not approved
  • Primary navigation guidance on RF legs must be shown on an EHSI indicator with auto-slew capability turned ON
  • GTN Moving Map, EHSI Map, or Distance to Next Waypoint information must be displayed to the pilot during the RF leg when flying without the aid of the autopilot or flight director.
  • The active waypoint must be displayed in the pilot’s primary field of view…

2.13.1 RNP 1.0 RF Leg Types
AC 90-105 states that procedures with RF legs must be flown using either a flight director or coupled to the autopilot.

This STC has demonstrated acceptable crew workload and Flight Technical Error for hand flown procedures with RF legs when the GTN installation complies with limitation set forth in Section 2.12 of this document. It is recommended to couple the autopilot for RF procedures, if available, but it is not required to do so. See section 4.5 of this manual to determine if this capability is supported in this installation.

At present, only a few non-AR approaches with RF legs meet the criteria in the STC and AC 90-105A. But RF legs could become more common on “standard” procedures to provide paths that offer better noise abatement, reduce airspace conflicts, and improve ATC efficiency, and pilots flying with GTN avionics (or similar navigators offered by other manufacturers) will be able to fly those procedures.

Updated AC 90-105A

FAA has published AC 90-105A – Approval Guidance for RNP Operations and Barometric Vertical Navigation in the U.S. National Airspace System and in Oceanic and Remote Continental Airspace (PDF available at the link).



This update to the previous edition (published in 2009) contains many important changes for pilots who use GPS to navigate under IFR.

FAA is gradually adopting the concept of performance based navigation (PBN), which includes the old systems of area navigation (RNAV) and refines details of required navigation performance (RNP). For more details about these standards, see AIM Section 2. Performance−Based Navigation (PBN) and Area Navigation (RNAV).

Avoiding Confusion when Flying GPS Legs

Garmin has published a useful document on the topic of the types of legs that appear in various instrument procedures.

For example, many departure procedures include fix-to-altitude legs.


GNS 400(W)/500(W) Series and GTN 6XX/7XX Series Instrument Procedure Leg Awareness (PDF) is a good summary of key types of legs that are used in DPs, STARs, and approaches, and it describes the features and limitations of the GNS and GTN units.

You can also find information on IAP legs in Chapter 6 of the Instrument Procedures Handbook.

Changes to Vectors-to-Final in Garmin GTN System 6.x

Garmin has released updated system software (version 6.11) for the GTN series of navigators. The software includes several new features. One of the changes, at least for day-to-day operations for typical general aviation pilots, involves the behavior of the vectors-to-final option (VTF) available when loading an approach.

To learn about and practice using the new features in GTN system 6.x, download the latest version of the free GTN 750 PC Trainer Lite from Garmin. The download includes updated manuals (PDFs) for the GTN series avionics that describe the new features in version 6.x.

The updated Pilot’s Guide for the new system software notes that “all waypoints along the final approach course, including waypoints before the FAF, are included in the flight plan.”


As I noted in Avoiding the Vectors-to-Final Scramble, current versions of the system software for Garmin GNS and GTN units remove all fixes except the FAF and the MAP when you choose VTF:

When you load an approach into your IFR GPS box and choose Vectors-to-Final, the computer typically erases all fixes except the FAF and the MAP, making the snazzy moving map far less useful as an aide to situational awareness. Vectors-to-Final also may lead to a frenzy of knob turning and button pushing if ATC unexpectedly clears you to an IAF or IF instead of setting you up on a heading to intercept the magic magenta extended centerline that Vectors-to-Final draws on your screen.

A note in AIM 5-4-6 Approach Clearance recognizes this issue:

Selection of “Vectors-to-Final” or “Vectors” option for an instrument approach may prevent approach fixes located outside of the FAF from being loaded into an RNAV system. Therefore, the selection of these options is discouraged due to increased workload for pilots to reprogram the navigation system. (AIM 5-4-6)

For that reason, like many instructors, I’ve long recommended against using VTF, especially because ATC can clear an RNAV-capable aircraft direct to an IF or to a fix between the IF and the FAF on any approach (again, see AIM 5-4-6).

For more information, see also Flying Instrument Approaches without Activating the Approach here at my blog.

The change in behavior in GTN units updated to system 6.x may change that recommendation, at least when flying some approaches.

Example: Flying the New VTF

Consider the RNAV (GPS) Y RWY 16R approach at Paine Field (KPAE) north of Seattle, home of the Boeing wide-body aircraft factory that produces the 747, 767, 777, and 787 models. It’s a typical RNAV approach.


If you fly the approach with the current system software for a Garmin GNS or GTN navigator, selecting the VTF option removes all of the fixes except for ITIPE (the FAF) and RW16R (the MAP). The map shows a magenta line extending from the MAP, through the FAF, and out along the final approach course north of the runway. If ATC clears you to EYWOK (an IF/IAF), you must reload the procedure and choose EYWOK as the transition (or ask for a new clearance).

If you choose VTF in an updated GTN navigator, however, the new system software includes all of the fixes along the final approach course, from EYWOK to the MAP at the runway threshold. The FAF, in this case ITIPE, becomes the active waypoint in your flight plan.



And the map shows a magenta line extending from ITIPE out to EYWOK, providing a reference as ATC vectors you to intercept the final approach course.


At this point, I’m still waiting for Garmin to release the new GTN system software and have it installed on my GTN 750. But my tests with the Garmin training software suggest that VTF may become a useful feature when flying some approaches.

If you’re flying with current system software or with a GNS-series unit such as GNS 530 or GNS 430, however, you should follow the recommendation in the AIM and in Avoiding the Vectors-to-Final Scramble to help you stay ahead of the airplane—and your avionics–when flying approaches.

For more information, see also Flying Instrument Approaches without Activating the Approach here at my blog.