Page 41 - Volume 16 Number 10

NATIONAL BUSINESS AVIATION ASSOCIATION • focusprior to using the electronic devices. In that draft, the FAA also proposed a requirement for all Part 91-F operators of large or turbine-powered multi engine aircraft, or fractional ownership program aircraft, to undergo a rigorous approval process - essentially what is required under Part 135, and for Part 91 Subpart K fractional companies - before the FAA would approve the use of their EFB.NBAA quickly joined with other aviation organizations in commenting on the draft AC, noting such requirements would add a new regulatory burden for many pilots as Part 91-F currently allows the pilot in command to approve use of any personal electronic device (PED) onboard an aircraft as long as the device doesn’t interfere with the aircraft’s electronics or communications systems. The draft AC also contradicted a May 2011 FAA Information for Operators (InFO) notice regarding use of PEDs that specifically states, “For part 91 operators other than 91K, FAA authorization for use [of an EFB] is not required.”The initial language confused many operators wondering if they could use an iPad in the cockpit, or who were seeking to utilize the proper channels and procedures to have their EFB use approved. “NBAA and its Membership are committed to working with FAA to develop policies that recognize the tremendous operational and safety benefits that EFBs are providing to pilots,” wrote Doug Carr, NBAA Vice President, Safety, Security & Regulation, in the association’s comments on the draft AC. “Many NBAA member companies are safely using EFBs and have developed robust operational procedures to support use of the devices.”The FAA took those concerns into account, as reflected in its recent advisory circular. Peter Korns, NBAA Operations Service Group specialist, noted the revised guidance again states that formal FAA approval is not required for use of EFBs under normal Part 91 operations, as longas the device does not replace any systems or equipment required by regulation.The AC does, however, advise Part 91F operators to document the process used to select their EFBs, and how those operators determined the EFBs complied with regulations. “Operators that are currently using, or plan to use, EFBs in the cockpit need to follow some transitional and operational record-keeping practices related to certain compliance and safety issues,” Korns added.In addition to clarifying Part 91-F procedures, the AC also addressed other compliance and regulatory questions. For example, it suggests that operators use secondary backup sources of aeronautical information - such as paper-based charts, or a secondary EFB - when conducting validation trials. The revised AC also outlines the processes that operators may use to ensure that use of the EFB does not interfere with other electronic systems onboard the aircraft.The advisory circular also advises operators to document and use a maintenance plan for the lithium-ion batteries used in many handheld devices, which may become volatile under some conditions. Lastly, the AC states operators are not required to conduct rapid decompression tests on each EFB used in their operation, and that operators may obtain documentation from the EFB manufacturer or vendor that the device successfully completed those trials.Korns reiterated that, while the advisory circular does not specifically apply to Part 91 operations other than 91F and 91K, the guidance should still be consulted as a reference by all pilots. “While advisory circulars are in fact advisory in nature, they do represent FAA’s view, and operators are strongly urged to follow the documentation and testing guidance to ensure the safe and effective use of this technology,” he added.Formal approval is still required for EFB use by Part 135 and other certificated operators through the issuance of OpSpec A061. mOCTOBER 2012 TWIN & TURBINE • 39