__”You’ve got JeppView on an MX20 and you’re still carrying paper charts?” Jim Miller asked. “Why?”
Jim Miller is executive vice president of Flight Options, the company that offers fractional shares of new and pre-owned business jets. Flight Options went “paperless” by providing the pilots of its fleet of 200 airplanes with electronic flight bags (EFBs) that are essentially Fujitsu pen tablet computers modified by Advanced Data Research (ADR). The EFBs eliminate most paper, including paper approach charts and, perhaps more important, the need to insert the periodic revisions into the manuals.
I didn’t have a good answer to Jim’s question. And frankly, I wasn’t sure whether it was legal or not to fly without current paper charts. With the advent of GPS navigators with extensive databases and moving map displays, it’s a question that frequently turns up in chat rooms on aviation websites. It turns out that for most Part 91 operations there’s nary a mention of charts in the regs. “Yeah?” you ask, “What about FAR 91.503 (Flying Equipment and Operating Information), which states very clearly that pilots have to carry charts?” True, but that’s in Subpart F and applies only to pilots of “large and turbine-powered multiengine airplanes.”
According to Part 91.503, “The pilot in command of an airplane shall ensure that the following flying equipment and aeronautical charts and data, in current and appropriate form, are accessible for each flight at the pilot station of the airplane.” Among other items required, it specifies under paragraph (3) “pertinent aeronautical charts” and under paragraph (4), “For IFR, VFR over-the-top, or night operations, each pertinent navigational en route, terminal area and approach and letdown chart.”
It can be argued that since the FARs clearly specify the need for charts in 91.503 but don’t in any of the sections of Subpart C (Equipment, Instrument, and Certificate Requirements) then charts aren’t required for small airplanes.
So, according to the FARs, if we’re flying a “small” airplane under Part 91, there’s no specific mention of a requirement to carry charts. Nevertheless, there are two sections that might be construed to suggest the need for charts. FAR 91.103 (Preflight Action) states, “Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include … for a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC …” The rule goes on to indicate that the pilot must be familiar with runway lengths at the airports of intended use and takeoff and landing distance requirements. While it does indicate specific information that’s required, the rule does not specify that the pilot carry charts, current or otherwise.
The other section of the FARs that a fussy bureaucrat might cite is the catchall 91.13 (Careless or Reckless Operation), which warns, “No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.” But that regulation probably won’t be called into question unless something goes seriously wrong, and in that case it’s doubtful that the lack of a current chart will be cited as a causal factor.
Whether those regulations apply or not, there is one that does apply to portable devices you use in your airplane. According to 91.21, “No person may operate, nor may any operator or pilot in command of an aircraft allow the operation of, any portable electronic device on any ? aircraft while it is operated under IFR?” unless “the operator of the aircraft has determined [the device] will not cause interference with the navigation or communication system of the aircraft on which it is to be used.”
But wait a minute. How could Flight Options, which operates “large and turbine-powered multiengine” airplanes have gone paperless? What about 91.503? It turns out that even Part 91 operators that come under Subpart F are not required to carry paper charts. The requirement only specifies the charts be in an “appropriate form,” not that they be paper charts. It would appear that the question becomes what constitutes an appropriate form.
The FAA has accepted a “form of charts” developed by Jeppesen, which produces the charts, and Marinvent, which developed the tool command language (TCL) vector graphics technology that it licenses to Jeppesen. TCL allows the charts to be displayed on certain portable and panel-mounted devices, including the UPS-AT MX20 multifunction display and others, such as those offered by Fujitsu, Northstar, Universal, Flight Deck Resources, Advanced Data Research, Collins and Spirent. All are capable of sufficient resolution to display approach charts and can use the JeppView FliteDeck application. JeppView subscribers are sent CD-ROM disks every two weeks that include all the current approach charts, airport diagrams and SIDs (DPs) and STARs. The service eliminates the time-consuming need to insert revisions into manuals.
The electronic charts are only one aspect of the “paperless” cockpit. Technology has allowed the development of complete “electronic flight bags” that are able to store and display many of the other printed materials that are typically carried in the cockpit. Eventually electronic displays are expected to be able to offer six pivotal “hosted applications”: moving maps with own position, up- or downlinked weather, traffic, terrain, wake vortex visualization and the depiction of temporary flight restrictions (TFRs).
For example, the Fujitsu EFBs in Flight Options’ airplanes, in addition to displaying the approach charts, include everything needed to maintain or operate the airplane, including aircraft minimum equipment list, maintenance manuals and wiring diagrams. “Our airplanes have no home base,” Miller pointed out, “So when an airplane breaks down, the local service provider probably won’t have the technical manuals available. But they’re all available on the CDs that are carried on the airplane and in the Fujitsu [EFB].”
The EFBs don’t only help when an airplane is grounded because of mechanical difficulties. They are also instrumental in keeping airplanes available. According to Miller, Flight Options’ Gulfstreams carried 39 paper chart binders and the Beechjets had nine binders. “It’s not only the weight we’ve eliminated,” he said, “but also the time the pilots spent updating the manuals, which is considered part of their duty time. With the EFBs, we save between half a million and a million dollars a year because of the availability of the crews and aircraft. If we have to charter a Beechjet to meet our obligation to a client, it costs us $10,000 per day; a Gulfstream costs us $70,000 a day to charter. And the need to charter may not be because an airplane’s down, but because the crew was unavailable because of the time they spent updating manuals.”
With the proliferation of EFBs, the FAA released an Advisory Circular (AC 120-76) on July 9, 2002, titled “Guidelines for the Certification, Airworthiness, and Operational Approval of Electronic Flight Bag Computing Devices.” (A revised version of the AC that will “smooth some of the rough edges” and meet some of the concerns of the airlines is expected to be out by January.)
The advisory circular divides the EFBs into three classes: Class 1 portable electronic devices (PEDs), Class 2 PEDs, which are portable devices connected to an aircraft mounting device, and Class 3, which are installed electronic devices requiring FAA certification.
The guidance material in the advisory circular applies to operators under Part 121 and 135 and to the operators of large and turbine-powered multiengine aircraft operating under Subpart F. According to the AC, “Other Part 91 operations do not require any specific authorization or aircraft certification design approval for EFB operations provided the EFB does not replace any system or equipment required by the regulations.”
The advisory circular points out that “during the transition period to a true paperless cockpit, an operator will need to establish a reliable back-up means of providing the information required by the regulations to the flight crew. During this period, an EFB system must demonstrate that it produces records that are as available as provided by the current paper information system. If an operator wants to transition to a paperless cockpit, an acceptable process should be developed with the operator’s POI [principal operations inspector].”
Assuming you can fly without charts-current or otherwise-is it prudent or safe? It probably depends on the rules you’re operating under and how far from home you’re straying. Depending on the database in your EFB/GPS you may have everything you need as long as it keeps functioning properly. The MX20/GX60 GPS in my Cardinal’s panel, in combination with the Jepp FliteDeck, displays not only the actual approach charts, SIDs, STARs and airport diagrams (with the airplane icon in position), but also terrain, geographic features, airways and airport information; it’s able to function as either a virtual sectional or en route chart. That’s fine as long as the equipment continues working-and so far it has-but if I’m relying on the electronics for all my data, I could be up the airway if it flies off into the sunset. That’s a good argument for either back-up charts or a back-up GPS.
The safety of your flight may well depend-as long as it functions properly-on the database in your GPS. According to a “position paper” published by Jeppesen, “Many of the systems available today make it all too easy to forget that paper en route, departure, arrival and approach charts are still required and necessary for flight.” Jepp goes on to state, in boldface, “Avionics systems, flight planning computer mapping systems, and associated databases do not provide all of the navigation information needed to conduct a legal and safe flight. They are not a substitute for current aeronautical charts.” It should be noted that Jeppesen wasn’t talking about its JeppView FliteDeck system when it wrote the advisory to subscribers of its paper charts.
According to Jeppesen, there are a number of reasons why GPS databases may not be adequate to replace paper charts. “Not all instrument flight procedures can be coded into a navigation database; step-down fixes between the final approach fix (FAF) and missed approach point (MAP) are not included in navigation databases; point-to-point navigation systems are generally not able to use route legs that are not defined by geographic points on the ground; you may not be authorized to fly all procedures in your database. If you don’t have a paper chart for it, you are not authorized to fly it; some categories of controlled airspace are not in your database”; and finally, “Not all altitudes are in your database.”
In summary, Jeppesen asks that pilots remember:
- Always fly IFR flight procedures as charted. DO NOT follow the database point-to-point without reference to the chart.
- Be aware that your database may not contain every SID (DP), STAR and approach procedure.
- Be aware that your database may not contain every leg or segment of the procedure you are flying.
- Not everything you need is in your database.
- Always confirm that the waypoint or navaids you retrieve from the database is at the location you intended.
- GPS, FMS and electronic map displays with associated databases are not a substitute for current aeronautical charts.
To carry charts or not to carry charts? That is the question. The answer, it would seem, is whatever you feel comfortable with. Despite its success with EFBs?Flight Options recently flew past the million-hour mark with its electronic flight bags?Miller said that it still carries paper copies of the emergency checklists and the airplane flight manual (AFM). “We’re still not comfortable about cutting the cord there,” he admitted.
So the choice is yours. You’re the pilot in command. But verbum sat sapienti?a word to a wise man is (or should be) sufficient.