March 1, 2011
By John S. Yodice
The glass cockpit has raised this frequently asked legal question: Do I need to carry paper aeronautical charts on a typical general aviation flight (noncommercial, under FAR Part 91) if I have the same information on electronic cockpit displays? IFR or VFR?
The short answer is, no. You may substitute an electronic display of the information in the place of paper navigation charts during all phases of flight operations. The decision whether or not to carry back-up charts is up to the pilot in command. No formal FAA operational approval is required. But the more complete answer has some very important caveats.
For both VFR and IFR, the most relevant regulation is FAR 91.103, which in general terms requires “that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.” The regulation then gets specific about certain required information such as weather reports and forecasts, fuel requirements, traffic delays, and required runway lengths. There is no specific mention of aeronautical charts, although they would obviously be included within the phrase “all available information.” There is nothing in the regulation which suggests that the aeronautical chart information needs to be in paper form.
On the other hand, for certain Part 91 aircraft, aeronautical charts are specifically mentioned; that is, for large and turbine-powered multiengine airplanes and fractional ownership program aircraft. In those cases, FAR 91.503 does require that “pertinent aeronautical charts” be accessible at the pilot station of the airplane (also see FAR 91.1033). Again, however, nothing in these regulations suggests that the aeronautical charts need to be in paper form.
However, we do get considerable help in interpreting these regulations from “advisory” material published by the FAA. Advisory Circular No. 91-78, “Use of Class 1 or Class 2 Electronic Flight Bag,” under the heading of “Removal of Paper from the Cockpit for Operations under Part 91” says that “EFBs/ECDs [meaning electronic flight bags and electronic chart displays] can be used during all phases of flight operations in lieu of paper reference material when the information displayed meets the following criteria: (1) The components or systems onboard the aircraft which display precomposed or interactive information are the functional equivalent of the paper reference material. (2) The interactive or precomposed information being used for navigation or performance planning is current, up to date, and valid [the emphasis is mine].” Within the terms of the AC, electronic flight displays can be portable (Class 1), attached to a mounting device (Class 2), or built into the aircraft (Class 3). It seems clear that Class 1, 2, and 3 displays are not required by regulation to have paper backup.
Since the decision to dispense with back-up aeronautical charts is up to the pilot in command, the FAA does offer some caveats. The agency recommends that pilots transitioning to a paperless cockpit should undergo an evaluation period during which the pilot carries readily available paper backups of the material. During this period the pilot should validate that the electronic information is as available and reliable as the paper-based system being replaced. Even beyond an evaluation period, and more generally, the FAA also suggests that a secondary or back-up source of the information be available to the pilot, either in traditional paper-based material or displayed electronically by other means.
With respect to portable electronic flight displays, and ones attached to a mounting device, there are certain technical requirements. A portable display that is not attached to an aircraft-mounting device may be used without backup as we have discussed, but additionally it must not be dependent on a dedicated aircraft power source or input from navigation equipment. But it may connect to aircraft power through a certified power source, such as a cigarette lighter. If an electronic flight display is to be attached to a mounting device, the mounting device must be approved for installation in the aircraft. If it is to receive power from the aircraft, there must be protection against short circuits with a circuit breaker or fuse. If it is to receive position information from an onboard navigation system, it must not adversely affect the output of the navigation source. Recall that under FAR 91.21, the pilot in command must affirmatively determine that the use of any portable electronic device (with certain exceptions not relevant here) will not cause interference with the navigation or communication system of the aircraft on which it is to be used.
Bottom line, with some caveats and technical requirements, back-up aeronautical charts are not required to supplement electronic cockpit displays of current and valid aeronautical charts.
AOPA’s legal counselor, John S. Yodice, is a private pilot who owns a Cessna 310.
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