EFBs

Replacing paper - Sources of aeronautical information and primary means of navigation: what are the rules?

EFBs, Navigation

Tuesday 13 March, 2018

RAAus is frequently asked about the rules regarding Electronic Flight Bag (EFB) or flight planning software and tablet usage; is it legal? Do I need a paper backup? We get asked these questions a lot and it leads us to believe that there is some degree of confusion amongst pilots and local authorities, with some people relying on out-dated or inaccurate information. So this information will explain the rules around EFB usage and provide members with the exact references for where to confirm them for yourself. Now to be upfront, this subject has the potential to be like eating Weetbix with no milk, but we will do our best to keep it interesting!

Aside from the questions we get on this topic, we need to get this information out there because we have read, seen and heard various people (including within the regulator) spreading misleading information about the legality of EFB usage. We also come across people every now and again who try to dissuade other pilots from using EFBs for various ill-founded or misunderstood reasons. It is usually not their fault as it can be tough to pin down the rules on new technology like EFBs and in the absence of definitive guidance people tend to want to keep things the way they have always been done. Let’s briefly put to bed one of the major reasons some are on the wrong side of history with respect to EFBs which is their potential limitations.

Like pretty much everything in aviation, EFBs have limitations which if poorly understood and left untreated, can cause safety issues. But paper is not vastly different in this regard, it is just that people are used to paper’s limitations thus give them little thought day to day.

For those who grew up flying with ‘paper’ products, ask yourself; Ever had a paper map fly out a vent or open window, or blown in to the back seat out of reach? Ever had an air-conditioning vent spew ice and water on to your map, rendering it a soggy, unreadable mess? Ever gone to fold a map only to have it split as a result of being folded one too many times? Ever inadvertently flown with an out of date map, ERSA or approach plate? Ever opened your flight bag only to realise the one map or chart you need isn’t in there at a crucial time? We have all these things happen at least once in our careers. This small list of problems is exclusive to paper products and pilots had for years accepted these limitations and worked around them, probably without even realising; keeping maps deliberately away from vents, pointing A/C outlets in safe directions, taking care when folding maps, having a disciplined pre-flight NAV bag check are all steps pilots would take without giving it too much thought – it is the way we have always done it.

The good news is that managing the limitations of EFBs is no harder, but it does require a different way of thinking. Overheating, battery limitations, lack of impact resistance, data updates, these things are all limitations exclusive to EFBs which can be just as easily overcome through good practice and developing sound procedures, just like pilots have done with paper since the dawn of aviation. The modern pilot can easily set themselves up for success through having a heat resistant tablet cover, carrying spare batteries or have charging in the aircraft, smart ‘screen’ toggling, impact resistant covers, deliberate EFB pre-flighting – none of these mitigating actions is significantly more burdensome than what the pilots of yesteryear had to deal with, they are just different.

Map

Maps can deteriorate quickly making them hard to read, especially in low light conditions.


So with that out of the way, what exactly are the rules for using an EFB? Let’s explain it to you using the type of questions we typically get on this subject.

I am flying privately under the IFR/VFR. Can I use an EFB as the sole source of my maps and charts? Yes! For private operations, an approved EFB may be relied upon as the sole source of aeronautical information to a pilot in flight. (Ref CAR 233, CASR part 175, Electronic Transactions Act 1999)

Dash

 

What is an approved EFB? An ‘approved EFB’ is technically a type of ‘approved service’ which can be used by Data Service Provider (DSP) to transmit aeronautical information. Importantly, a DSP must have been approved by CASA and issued a CASR Part 175.295 certificate. As an example OzRunways, Avsoft or AvPlan and Jeppesen are approved in Australia by CASA.

An Aeronautical Information Service (AIS) could also technically produce an EFB. There is only one AIS in Australia however, Airservices Australia, and they don’t produce an EFB. The list of DSP’s can be found here. (Ref CASR Part 175)

Do I need a backup if I use an EFB? Legally, there is no requirement mandating the carriage of a backup for private operations. However, it is so easy to have one and good airmanship suggests it is a great idea, so why wouldn’t you? RAAus recommends that for VFR flights outside of your local area that you carry an appropriate backup (see later paragraphs for more information). If you are privately flying IFR in IMC, RAAus recommends carrying a second tablet, as using a chart on a phone whilst not impossible, is difficult.

If I carry a backup, does it need to be paper or can I use another tablet/phone? What is appropriate? There is no requirement to use paper charts as a backup to an EFB. Another EFB (either on a tablet or phone) is more than appropriate as a backup. This is reason subscriptions with software providers often give you access to the app on one tablet and one phone, so you have a backup. Remember though, if you use another device running software as a backup, make sure it is charged and up-to-date before you go flying, just as you do with your primary EFB.

 

CBR

Luckily tablet failures are very rare, but why not carry a backup?


Isn’t a phone too small to use as an EFB? Is there a lower size limit for an EFB? There is no legal minimum size but CASA state that greater than 200 mm diagonal for screen size is recommended. The iPad mini meets this minimum suggested screen size. A phone is typically smaller than 200 mm diagonally, but for private operations it can be used as a backup; it will do the job in the unlikely event you needed it – just beware a phone is much harder to use, especially in turbulence. RAAus doesn’t recommend using a phone as a primary EFB device.

Can I get in trouble at a Ramp Check with CASA if I rely solely on software and a tablet? No. It is legal to rely on software as your sole source of aeronautical information, however if you get ramp checked you must be able to demonstrate that your software complies with the requirements of CAR 233. This includes having the required maps and charts downloaded to the device (On demand downloads do not satisfy this requirement), plus sufficient charge on your device to conduct your intended flight. The introduction of the Electronic Transactions Act 1999 means that electronic documents are every bit as valid and legal as paper documents – hence why information on a tablet, from an approved source is legal.

Can I keep my flight log in software and a tablet? Do I need to keep a paper flight log? You can keep your flight log on software and a tablet. There is no need to keep a paper flight log, unless you want to. To quote CASA on the subject (From CAAP 233):

‘The Acts Interpretation Act 1901; and the Electronic Transactions Act 1999 are the enabling legislation allowing the use of digital media to display the documentation required by the Civil Aviation Act 1988 and any of its subordinate regulations’

It is quite clear – you can keep a log digitally and a ramp check should recognise using your iPad to log your times and fuels.

What is CAR 233, what does it say and how do I find it? You can find CAR 233 here or your software providers may include it in their aeronautical information. CAR 233 states a pilot must ensure that before commencing a flight that any aeronautical data and information required is carried in the aircraft and readily accessible to the flight crew. (Ref CAR 233)

What aeronautical information and data is required for a flight? CAR 239 provides the requirements for planning by a pilot. The aeronautical data and information you require is that which is applicable to the route to be flown and to any alternative route that may be flown, and this data must be published by a Data Service Provider (CASR Part 175.295 certificate holder, such as OzRunways, AvPlan or Jeppesen) or AirServices Australia. Think along the lines of maps, approach plates, ERSA, etc. You can always discuss with a local flying instructor if you aren’t 100% sure. (Ref CAR 233, CASR Part 175)

I still feel more comfortable flying paper maps and charts though…maybe just as a backup. When it comes to someone still wanting to use paper, it is a simple answer: If you are not yet comfortable jumping straight from paper to EFB, then you should carry paper with you as well until you are happy to go all electronic. Or if you prefer a paper back-up, then use paper as a backup until such time as you feel it isn’t necessary.

Map 2

Still need paper? Your software provider may provide the option of printing from the application, however you must ensure the scale of the map is not altered. Check with your software provider to be sure.


Getting Started. We strongly recommend before you fly with an EFB for the first time you spend time with it on the ground getting used to it – check out how to video’s, attend seminars by the software providers, ask people in your local flying network for tips on how to set it up to suit your way of doing business. Also, it can help if you take some lessons with an instructor to get used to using an EFB (There is no specific EFB training requirement in the RAAus syllabus other than a reference to Use of electronic devices in Element 1.8 of the Cross Country syllabus). Long term the situational awareness benefits, ease of manipulation and immense data capacity of an EFB means it far outweighs using paper for aeronautical information.

Desk

Would you rather carry an iPad or a 9kg NAV bag with most of the AIP – EFBs can carry a substantial amount of data which is a benefit to private operators and commercial operators alike.


Cockpit

You know how much work is involved in updating AIP amendments! Moving to a paperless flight deck is worth the investment. Most software is versatile and suits everyone from the weekend trike flyer through to the IFR heavy flight deck.


Lastly, let’s talk about ‘primary means of navigation’ and EFBs. This phrase gets misinterpreted a lot, which is understandable given the phraseology can mislead pilots in to thinking that you can’t use software to gain navigation information. The question goes something like:

But I heard we can’t use (insert your favourite software provider) as the primary means of navigation, how can it be legal? The restriction of use for primary means of navigation is referring to specific navigation elements of the EFB: in particular, any device derived GPS position data such as your aircraft position, present latitude and longitude, HSI display etc. These features of any software can only be used as a supplement to your primary navigation source. They are there to enhance your situational awareness only – that is, treat the tablet position data as a ‘VFR GPS’.

As an example, you can’t fix your aircraft position by looking at the EFB, seeing the aeroplane symbol over a town and saying ‘the aircraft symbol says I am here, therefore I have fixed my position’ – that would be relying on the device GPS as a primary means of navigation which you cannot do. What you can do though is look at the EFB, see the aeroplane symbol over a town, assess the other features on the map around the town, look outside and do a Clock to Map to Ground visual pinpoint to fix yourself. Of course it is more than likely that your visual pinpoint will correlate with your tablet’s GPS position shown in the EFB. This is called using the EFB as a supplemental source for navigational information – it is there to assist you in position fixing and provide enhanced ‘situational awareness’ which can supplement your primary means of navigation.

When using EFBs, you must position fix using either a proper visual fix or approved NAVAID in accordance with the section of AIP relevant to your category of flight. Again though, don’t be confused – you can use the EFB to derive the aeronautical information needed to assist you to fix yourself though (i.e. the maps are legal to use to discern features, frequencies, etc.).

One thing it is worth reminding pilots of – the restriction on using software and tablets as the means of primary navigation also means your EFB GPS position isn’t a valid way of avoiding airspace (restricted or controlled) – you MUST avoid airspace using an approved means of navigation (and by the appropriate margin!).

Sunset

 

So to sum it all up – The Aeronautical information in EFBs approved by CASA is legal; it is good to go as a sole source for private operations, EFB GPS position information is only to be used to supplement your primary means of navigation.

Thanks for sticking with it if you got this far! Fly safe, see you at your next local air-show or fly-in.

Thanks to OzRunways for providing the basis of this article.