EFBs - New Advice From Our Friends At the FAA

Half Fast

Half Fast

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Half Fast
Anybody else been perusing the latest version of AC 91-78?

There's some stuff that, if I'm interpreting this correctly, makes me glad it's advisory and not regulatory. The FAA seems to go in circles through several ACs, using conflicting terms and contradictory statements. If you're interested, grab a pot of coffee and a bottle of extra-strength Tylenol. The AC, with its confusing and conflicting language, would upend the way we currently use our iPads and tablets if taken literally.

BLUF - This AC revision, taken at face value, will make any iPad or tablet or similar device an "installed" component if it's on a yoke clip or suction mount or if it's receiving GPS or other data from installed hardware. Being "installed" means it will require at least a logbook entry as a minor modification, and it might require an STC. Further, if it's "installed" you will need an A&P to make a logbook entry every time it goes in or out of your plane.

Previously, EFBs were designated as Class 1, 2, or 3, where class 3 EFBs were installed equipment requiring an STC. Now all EFBs are categorized as "Portable" or "Installed."

A few gems (and some comments):

10.1 Portable EFBs​
1. Not dependent upon a dedicated aircraft power source or input from navigation​
equipment to provide display functionality, although they may connect to aircraft​
power through a certificated power source;​
2. Not attached to an aircraft mounting device; and Sounds like it's only portable if it's on your kneeboard or held in your hand.​
3. Not connected with or receiving data from any aircraft system. Wouldn't this preclude getting GPS and traffic data from a Stratus ESG or similar?​

10.2 Installed EFBs​
1. Receive power from the aircraft that is derived from an electrical bus source protected​
against short circuits with an appropriately rated circuit breaker or fuse;​
2. Receive position reference from an onboard navigation system, provided such input is​
designed and integrated in such a manner as to not adversely affect the output of the​
navigation source to which they are connected; and Looks like using wifi from an onboard GPS makes the EFB "installed."​
3. Be attached to a mounting device provided that such device is approved for​
installation into the aircraft (e.g., if intended for installation into a type-certificated​
aircraft, then such mounting device must meet the requirements of 14 CFR part 21,​
§ 21.303). This would seem to include ram mounts, suction cups, yoke clips, etc., but what does "approved" mean here? Is an STC required?​
4. Refer to AC 20-173, Installation of Electronic Flight Bag Components, for complete​
details for installation of EFB components. Here we start down a rabbit trail. AC 20-173 further refers to AC 120-76 which in turn points back to AC 20-173. AC 120-76, though, seems to conflict with AC 91.78A by calling out the stuff we've counted on all along. IOW, 120-76 tells us:​
In the context of this AC, EFB​
equipment components supporting EFB applications are “installed” when they are​
incorporated into aircraft type design under 14 CFR part 21, or as a proper alteration​
under 14 CFR part 43, § 43.3. All other components supporting EFB functionality are​
considered “portable,” regardless of how often they are removed from the aircraft. In​
order for portable EFB hardware to support EFB applications, installation of at least some​
EFB components may be required, depending on requirements for positional integrity​
(e.g., installed mounts), continuity of power (e.g., dedicated primary power port), and​
data connectivity (e.g., Wireless Fidelity (Wi-Fi ®​
), and Ethernet). Airworthiness​
regulations do not apply to portable EFB components other than for specifications​
associated with the installed components (i.e., mounting (size and weight), power​
(maximum electrical load, voltage, and current frequency), and data connectivity...​
120-76 also (blessedly) tells us:​
9.1.2 Portable EFB Hardware Components:​
• Must be capable of being easily removed from or attached to their mounts by​
flightcrew member personnel without tools or maintenance action.​
• Can be temporarily connected to an existing aircraft power port for battery​
recharging.​
• May connect to aircraft power, data ports (wired or wireless), or installed antennas,​
provided those connections are installed in accordance with AC 20-173.​
​
So we have 91-78 telling us that if an EFB uses a mounting device it's "installed," whereas 120-76 (a third-level reference) tells us those mounting components are only installed when part of the type design or incorporated as an approved alteration (I'd assume a "minor alteration), and the components are portable if they can be easily removed without tools or maintenance action.

91-78 says a portable device can't connect to aircraft data, whereas 120-76 clearly says it can.

There's also what I hope is poor wording in 91-78 part 9.1:
2. The EFB system on board the aircraft displays only information which is functionally​
equivalent to the paper reference material which the information is replacing or is​
substituted for.​
That "only" seems nuts. Taken literally this would mean that the EFB system cannot display (for example) ADSB traffic or weather.

What a mess.

For now, I plan to ignore this advice and to continue connecting my iFly 740b to my Stratus ESG via wifi and plugging its power cord into my plane's cigarette lighter and enjoying the capabilities and enhanced safety it gives me.
 
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That’s a lot of different font colors to make a point.
 
Racerx said:
This is what happens when you let people who have never used these things in a practical environment write things for the people that do.
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:yeahthat:

It's really pretty clear that they have no idea what's already been on the market for years, what's widely used in real-world applications, and how these things contribute to safety. I know we can't force all these guys to be pilots, but they should at least be required to log a number of cockpit familiarization hours every year so that the might have some clue how things really work.
 
midwestpa24 said:
Just my short read, but I would view an iPad as a PED, not an EFB, by the definition listed in that AC.
Click to expand...
Yeah after looking through the whole document, I would agree with that. I suspect this is targeted at commercial operators more than private pilots.
 
midwestpa24 said:
Just my short read, but I would view an iPad as a PED, not an EFB, by the definition listed in that AC.
Click to expand...

It seems to be a matter of application.

7.1 Electronic Flight Bag (EFB). An electronic display system intended primarily for flight deck or cabin use. A portable or installed EFB can display a variety of traditional paper information (e.g., checklists, aeronautical charts, and pilot’s operating handbooks (POH)) and/or complete algorithmic functions (e.g., deice holdover times, Weight and Balance (W&B), performance, and fuel calculations).​

iPads are used in cockpits for those functions. The terms aren’t mutually exclusive. PEDs can be used as EFBs.

And what about dedicated portable devices like Garmin Aeras and iFly 740s?
 
cowman said:
Yeah after looking through the whole document, I would agree with that. I suspect this is targeted at commercial operators more than private pilots.
Click to expand...

That would be nice, but it doesn’t seem to say so.
 
I think you're misreading it. I read it as the FAA trying to narrow the definition of installed devices and broaden the scope of portable devices.
 
10.1.2 - Sounds like a permanent dock type of situation, not a clip
10.1.3 - No, a Stratus is not an aircraft system, it's a portable system, too. A Garmin panel mount something or other would be.

Something like this: installed, it's tied into aircraft systems and displays information directly from the flight computers

An ipad on Ram mount receiving no information from anything permanently mounted in the aircraft, portable.
 
Sierra_Hotel said:
An ipad on Ram mount receiving no information from anything permanently mounted in the aircraft, portable.
Click to expand...

An Aera mounted in the panel with a power and RS232 connection allowing it to receive flightplan changes? Or same with Bluetooth connectivity?
Panel mounted iPad also with Bluetooth connectivity to installed boxes either directly or via Flightstream?

I will ignore this as well:
1e12036a3ed31f7f05fc49d2e6659026.jpg
 
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FWIW, my take…

The portable vs installed probably just reflects similar language in AC120-76. Combined with the “connected” discussion, it sounds very restrictive. It makes it sound like an iPad running Foreflight, Garmin Pilot, etc is a "portable" EFB if running under its own power, on your lap and connected to a Sentry or portable GDL, but an "installed" EFB if plugged into the airplane system, receives GPS, TIS-B or FIS-B data from the panel, or uses FlightStream, or is on a suction mount.

But, poor writing aside, I doubt that’s the intent. "Mounting device" more likely means something like the Guardian smartPanel - the mounting device itself is installed in the aircraft panel.
1710245271508.png


I think “installed” and “connected” is ultimately about the reference to FAR 21.303, which refers to PMAs for accessories. Like the Guardian. Like FlightStream. Like Bluetooth from a Garmin or Avidyne navigator or audio panel. Like installed USB outlets. All of which are certified to provide those services to portable devices.

I think the idea is to say situations in which we pull some wires and create a hookup are verboten, not to preclude either a portable yoke mount or using our panels for what they were specifically designed to do.
 
Sierra_Hotel said:
No, a Stratus is not an aircraft system, it's a portable system, too. A Garmin panel mount something or other would be.
Click to expand...

Not all Strati are portables.

I use a Stratus ESG + GPS bundle, which is a Stratus xcvr paired with a GPS / ADSB receiver permanently installed in the plane, tied into aircraft power, and using a permanently installed antenna. My 740b and iPad connect to it over WiFi.

www.mypilotstore.com

Stratus ESG ADS-B in and out A&P Bundle (with GPS) for Certified Aircraft

ADS-B Out Transponder with WAAS GPS, Stratus 3i Receiver, wiring harness, and all of the mounting hardware.
www.mypilotstore.com www.mypilotstore.com
 
I think you're right about whoever wrote that not knowing the state of current tech. I believe they were calling out panel mounted equipment wired to gps equipment as @midlifeflyer suggests. I don't think they intended to mean stuff clamped on a yoke, or receiving data via wireless tech.

The author of this really needs to talk to the guy at the FAA that approved allowing the Avidyne to display traffic and weather from a portable adsb-in source. The author would probably be shocked by that.

They certainly didn't use any language that would make it clear they even considered wireless tech.
 
Has anybody suggested you [write] to the chief council for an interpretation yet?
 
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Salty said:
I think you're right about whoever wrote that not knowing the state of current tech. I believe they were calling out panel mounted equipment wired to gps equipment as @midlifeflyer suggests. I don't think they intended to mean stuff clamped on a yoke, or receiving data via wireless tech.

The author of this really needs to talk to the guy at the FAA that approved allowing the Avidyne to display traffic and weather from a portable adsb-in source. The author would probably be shocked by that.

They certainly didn't use any language that would make it clear they even considered wireless tech.
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Agreed.

I think the authors are woefully ignorant of current technology and how it’s actually used. Unintentionally (I hope!), they’ve written an overly restrictive AC.

But at least it’s not regulatory.
 
tsts4 said:
I'm going to pretend I never saw this thread.
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I have the same attitude, hence my last sentence:
Half Fast said:
For now, I plan to ignore this advice and to continue connecting my iFly 740b to my Stratus ESG via wifi and plugging its power cord into my plane's cigarette lighter and enjoying the capabilities and enhanced safety it gives me.
Click to expand...
 
midlifeflyer said:
But, poor writing aside, I doubt that’s the intent. "Mounting device" more likely means something like the Guardian smartPanel - the mounting device itself is installed in the aircraft panel.
Click to expand...

I hope you’re correct, but they did a bloody poor job of saying so. I’ll rely on AC 120-76 saying that portable components are those which go in and out of the plane without needing tools, and that data connections are okay. That makes much more sense.
 
Half Fast said:
I hope you’re correct, but they did a bloody poor job of saying so. I’ll rely on AC 120-76 saying that portable components are those which go in and out of the plane without needing tools, and that data connections are okay. That makes much more sense.
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And I think that's why it specifically refers to AC 120-76.

Since (like all ACs) it's nonregulatory guidance, we find the opposite in other FAA guidance, and I see the likelihood of my yoke mount and bluetooth panel connection causing a problem is ridiculously remote, it's not something which concerns me. I wouldn't wad my panties about it.
 
Salty said:
The author of this really needs to talk to the guy at the FAA that approved allowing the Avidyne to display traffic and weather from a portable adsb-in source. The author would probably be shocked by that.
Click to expand...
Or in the other direction.

I've been kicking around the idea of replacing my (flaky) single-band MLB100 with a dual-band Skytrax 200, and then relegating my current Stratux to be just a backup. If I had a reliable traffic/weather feed from the IFD540, I'd prefer to link my tablets to the IFD wifi so I can also exchange flight plans between iFly and the IFD.

But according to this AC, having the tablets consume data from an "installed device" makes them in turn "installed devices", which is just silly.
 
Jim_R said:
Having to make a logbook entry every time you "install" or "uninstall" your tablets in your plane?
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:yeahthat:

Or having to get an A&P to make the log entry, since it's at least a minor alteration. Or worse, all the different tablet mounts needing STCs, and then having to file paperwork every time your yoke mount goes in or out of your plane.
 
Jim_R said:
But according to this AC, having the tablets consume data from an "installed device" makes them in turn "installed devices", which is just silly.
Click to expand...

... and we all know the FAA would never do anything silly.
:rolleyes2:
 
I find that the FAA is usually reactionary to events happening in aviation. I'm not aware of any actual safety or flight issues caused by the use of a tablet consuming data from an installed device to help aid situation awareness, so I would assume that wasn't their intention. There is definitely plenty of evidence to the contrary. I do agree it's poorly written unless they actually intended to restrict the use of tablets as EFBs, which I suppose could be the case, but god help us if that's it.

Now if they're trying to somehow weed out the dingbats who think Foreflight's synthetic vision on an iPad is good enough to be a PFD, then maybe they're on to something.
 
It is amazing how much band width is consumed making a mountain out of a molehill.

BFD! It’s advisory. If one wants interpret it in the most restrictive way possible, please do so and attach the logbook entries so we can all be enlightened.
 
FYI: The definition of “installed” has not changed. It’s the same. What has changed is Part 91 owners have continued to move the line between installed and portable without understanding the ramifications of doing so.

In addition, cherry-picking one guidance document from the group of related guidance documents only creates more confusion for the reader. By simply reading all the guidance together as a whole you will find nothing has really changed for private Part 91 owners and the use of EFBs in the cockpit.

For example, you will find AC120-76 is not applicable to private Part 91 ops. And the answer to the “install” vs “portable” question which is applicable to private Part 91 owners was linked in the revised AC.

That answer is found in AC 20-173 and follows long standing guidance on what defines an installation. So unless an owner “incorporates” their EFB into the aircraft type design, i.e., installs it, via Part 21 or Part 43, the equipment is still considered “portable.”

In short, nothing has really changed other than the revised AC changes the terminology from Class 1 and Class 2 EFBs to portable and installed, and links EFB installation guidance to AC20-173. If anything, it simplified the guidance and process from my point of view.
 
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