New Terms And Concepts Included In The Updated Document
After over a year of work, the FAA has published a revised Advisory Circular (AC) that provides guidelines on the certification, airworthiness and operational approval of Electronic Flight Bags (EFB). While the information contained in AC 120-76B, is consistent with previous FAA information on this subject, there are a variety of new terms and concepts introduced in the AC.
During the development of AC 120-76B, NBAA provided comments to the FAA that detailed a number of concerns with the draft. Specifically, the AC sought to provide guidance for Part 91F (large and turbine-powered multiengine aircraft) operators that went beyond the guidance for other Part 91 operators. Despite the comments from NBAA and other industry stakeholders, the FAA elected to move forward with specific guidance for 91F operators.
Although the AC makes clear that "Part 91F operations do not require any specific authorization for EFB operations provided the EFB does not replace any system or equipment required by regulations", there are specific compliance items that operators are advised to document as they transition to EFB use. The AC does not specifically cover Part 91 operations (outside of 91F and 91K), but any operator planning to use an EFB is advised to review the document. Finally, the AC provides information to Part 121, 125, and 135 operators that require a specific OpSpec for EFB use.
The AC maintains the familiar Class 1, 2, and 3 criteria for EFB hardware and Type A, B, and C classifications for software. One important change is that Class 1 and 2 EFBs are both considered portable electronic devices (PED) unless they host EFB applications and meet other criteria specified in the AC. If a Class 1 or Class 2 device is considered a PED rather than an EFB, its use is generally restricted to cruise flight and/or above 10,000 ft. Operators should check with their EFB provider/software vendor to insure that the device they are using is classified as an EFB.
When a device is classified as an "EFB PED" operators are able to use the device in all phases of flight, but must follow the guidance in the AC to on items such as non-interference testing.
For Part 91F operators, EFBs can be used in lieu of paper reference material so long as the intended functions of the device meet criteria defined in the AC. During the paperless transition, it is the responsibility of the operator to develop an evaluation and transition plan as described in the AC. Certificated (i.e. Part 135) operators must obtain OpSpec A061 for EFB use. While no formal approval is required for Part 91F operators, adherence to FAA guidance should be documented.
Specific items to consider and document, include:
The operator must have a secondary or backup source for aeronautical information displayed on an EFB using Type A or B software. The secondary or backup information can be displayed electronically by other means.
The operator must be prepared to document compliance with items in subparagraph 13c of AC 120-76B. These items include EMI testing; proper stowage/mounting of the EFB; rapid decompression testing of representative device; policies for EFB use.
The revised AC makes clear that rapid decompression testing must only be accomplished on one representative sample of the make/model EFB that the operator plans to use. For example, many vendors are able to provide documentation indicating that they have performed rapid decompression testing on popular EFBs, such as the Apple iPad. So long as the operator can obtain this documentation, it is not necessary for testing to be performed on the specific devices used by the operator.