Use an iPad or other electronic flight bag (EFB) in the cockpit to pull up charts or instrument approaches? A proposed advisory circular could limit their use in the cockpit and stunt their growth potential under the Next Generation Air Transportation System. AOPA and the General Aviation Manufacturers Association are concerned that pilots wouldn’t be able to use EFBs below 10,000 feet or that they would need to go through substantial testing for each aircraft/EFB.
AOPA and GAMA on July 13 voiced their concern about many points in the proposed circular, “Guidelines for the Certification, Airworthiness, and Operational Use of Electronic Flight Bags EFB” and asked the FAA to go back to the drawing board.
“AOPA/GAMA believes that electronic flight bag technology will be a critical tool to enable many expected NextGen capabilities at an affordable cost; however, this proposed guidance material will limit much of that potential because of short-sighted perspective,” the groups said.
The circular would apply to “operational use” of all EFBs, not just those being used in situations that require “operational approval.” This change, the groups said, would greatly broaden the scope of many parts of the advisory circular to encompass Part 91 operations, along with Parts 121, 125, 129, and 135. AOPA and GAMA said that the circular should be clarified to limit the impact on Part 91 operations to subpart k only.
The groups also opposed some of the testing requirements listed in the advisory circular: “AOPA/GAMA believes that attempting to impose testing requirements on ‘off the shelf’ electronics which host EFB applications (such as charts and plates) at the individual operator level is a tremendous waste of resources. Many applications which can be hosted on an EFB simply don’t require such a level of scrutiny.”
The groups requested that the FAA consider all comments on the draft advisory circular to create a new, well-thought-out proposal and then open it to public review.