FAA Certification

To the delight of Jeff Geraci and other providers, electronic flight bags - EFBs - are past the fad stage and are now rapidly ridding cockpits of reams of paper, and helping ease graying pilots into the age of connectivity, digital documentation and business efficiency.

How much an EFB can change habits and procedures depends in many ways on how much an operator is willing to invest in the technology. Systems range in price from a few thousand dollars for portable units limited to displaying charts and electronic documentation, to tens of thousands of dollars for permanent fixtures that do all that, plus display an aircraft's position on charts, depict real-time weather in the cockpit, and tell the home base how much fuel has just been uploaded, among dozens of other features.

Geraci's company, Michigan-based Advanced Data Research, offers a one-week, $12,000EFB entry package, and his client list is testament to an emerging and expanding market. After only four years in the aviation business, ADR, where Geraci is vice president of business development, has sold more than 3,800 EFBs-2,650 of which are flying in turbine-powered bus i-ness aircraft including 470 with Raytheon's Flight Options fleet.

ADR, one of the largest providers of EFBs in the United States, is an "integrator" that modifies the screen brightness on commercial-off-the-shelf (COTS) pen tablet PCs and "bundles" the devices with ADR and Jeppesen software applications and electrical interfaces. Other integrators are similarly encouraged by the market products. ADR's most popular "solution" at the moment is the 2.6-pound, Pentium III-powered Fujitsu FG-3600 with 8.4- inch (diagonal) screen. Typically powered by a cigarette lighter adapter and strapped to the pilot's knee, the device hosts a wide range of graphic and computational pro-grams using Windows 2000 and an ADR-written software shell. ADR has two other more modern units available as well: the FG-5000, which costs another $1,000 and provides twice the screen brightness, and the more expensive FG-8000, which has a separate screen and computer unit for particularly cramped quarters like the front end of a Falcon 50 or Learjet.

Feedback from users is evidence of the life-changing impact of Geraci's $12,000/ one-week offer. The money buys two ADR-modified FG-3600s and the seven days is the time it takes to process the order, buy or modify a chart subscription from Jeppesen and complete some self-paced training.

Bob Hughes, head of Alcoa's corporate flight department, says he "hardly ever" uses his six FG- 3500s (forerunner of the FG-3600) in practice, but that the investmet buys him several hundred pounds of payload on every international flight and immeasurable relief in chart upgrading chores every two weeks. Hughes uses the EFBs as an electronic backup to printed approach charts for all Alcoa flights – and as an FAR Part 91 operator, he requires no FAA approval to do so. Instead, Hughes and his pilots print the charts for each destination airport from the same Jepp View software that runs on the EFBs, puts the sheets in a folder and throws them away after each leg is completed, eliminating clutter for the remain-er of the trip. The company has two FG-3500s on each of its three aircraft – a Bombardier Global Express and a Gulfstream IV and GV. "This way we have double coverage," says Hughes. By using the EFBs as a hot backup in case of an unplanned diversion or the misplacement of paper charts, the department is able to cut back from the usual 42 world-wide Jeppesen chart manuals to just seven, primarily keeping the en route and area charts that Jepp does not yet offer in digital format for EFBs.

Parenthetically, Jeppesen is in a unique and seemingly enviable position in this relatively new territory. "There's really no other company out there doing electronic charting," says Eric Anderson, Jeppesen spokesman, and as such, most integrators "bundle" their EFBs with JeppView FliteDeck, the Boeing unit's digitized and geo-referenced approach and airport chart service. The software evolved from JeppView, the 1996-released ground-based printing and viewing application in which users type in a route and the pro-gram prints out all of the needed charts, plus airport diagrams and alternates.

Though JeppView could be used on a laptop computer in flight, Anderson says pilots found the program to be "clunky." Two years ago, when Jepp discovered that pilots were beginning to carry tablet-type PCs like the FG-3600 along in flight, the company decided to build a new program specifically for displaying charts on an EFB. The subscription cost for the continental United States, updated every two weeks with a CD mailed by Jeppesen, is $840. International packages run roughly 10 times that cost. Anderson says Jeppesen "does not get involved in the hardware" but keeps track of which integrators are using its products. Much of the business, Anderson says, is coming from individual pilots who buy chart, flight planning and en route graphics program subscriptions and use the soft-ware on non-certified commercially avail-able EFBs.

But is that legal? John McGraw, man-age of the FAA's flight technologies and procedures division, says the FAA worked with industry for almost four years to come up with an Advisory Circular (AC) to address that question. "We recognized the EFBs were being used by airlines to begin with, so we tried to frame the AC around how they were being used."

Much of the work was done by the Air Transport Association's Digital Display Working Group and associated RTCA committees. Brian Uskoski, an airline pilot and chairman of the ATA group since 2002, says the AC is best viewed as a "sandbox" with the edges defined by the FAA and industry. "As long as you stay within the boundaries, creativity is the only limit," he says.

AC 120-76A, released in March, describes the sandbox for FAR Part 91, 121,125,129and 135operators. For pilots, a key piece of information in the 31-page document is a matrix that defines the required approval levels as a function of the EFB system's hardware and software characteristics. In simple terms, Class I hardware is portable but has no device (docking station, knee board, swing-arm or cradle) for mounting it in the aircraft and has read-only (one-way) connectivity to other aircraft systems; Class II generally has a mounting device, like a yoke mount or swing arm, but can still be portable; and Class III systems are installed equipment and usually swap data with either the FMS or EICAS, or both.

As for software, Type A is the least complicated, primarily offering the pilot electronic documentation like the flight information manual, standard operating procedures, minimum equipment lists and maintenance manuals, but no charts.

Type B software can show and do everything Type A does, plus display approach charts and checklists, calculate weight and balance, and deliver weather information and cabin video, among other features. However, Type B cannot be used to show aircraft position on approach and airport charts, an option pilots, especially on international routes, strongly favor. So-called "own-ship" position requires Type C software, which in addition to providing Type B features, meets stringent DO-178B assurances due to two-way communication with the FMS and other avionics. DO-178B generally requires integrators to write at least some of their own software to be able to prove to the FAA that the units do not interfere with critical aircraft systems. COTS software manufacturers, like Microsoft, typically will not divulge how their code works.

Though any class of hardware can theoretically host any or all software types, operators, EFB providers and installation shops generally talk about Class I, II and III EFBs with the understanding that:

  • A Class I EFB has Type A software and is generally used for viewing electronic documentation, etc.
  • A Class II system has Type B software and is used for viewing charts (in addition to everything the Class I device does).
  • A Class III EFB has Type C software and can display own-ship position and communicate with other aircraft systems such as the engines.

The AC says that to rely on an EFB instead of paper charts, an operator must demonstrate to the FAA that the paperless system "produces records that are as available and reliable as those provided by the current paper information." Some of the ways to meet this standard are through separate and backup power sources, or redundant EFB applications hosted on different EFB platforms. There's also a pseudo-paperless option by which paper charts are carried aboard as backup to the electronic charts.

For Part 91 operators, the AC applies only to those flying "large and turbine-powered aircraft" with specific functionality or equipage rules. For the rest of Part 91, there's no specific authorization required provided the EFB "does not replace any system or equipment required by the regulations."

That means a corporate operator like Hughes - who uses his FG-3500 as a backup - is unaffected, unlike Part 121, 125,129and 135operators who have to get the nod from FAA Flight Standards, FAA certification and the company's principal operations inspector (POI) to use Class II and III equipment. These days, Hughes is considered a minimalist given the abundance of capabilities possible with the FG-3500/3600and other units, the latest being the ability to download and display satellite weather every five minutes.

George Lupinacci, chief pilot for ant-her large corporation, uses his five knee-board-mounted FG-3500s from ADR as a substitute for all paper except en route and area charts - clearly Class II usage. The EFBs, which two years ago cost $6,500 each, are loaded with all approach and air-port charts, aircraft flight manual, mini-mum equipment list, quick reference handbook, minimum navigation performance and RVSM specs. From a regulatory standpoint, Lupinacci made use of the 337 form to hook up a power supply for the devices, a common practice for EFB users, both for the power and for mounting devices. Of his seven pilots, Lupinacci says he has "one or two" who prefer flying approaches with paper, so he carries print-ers in his two GIVs to accommodate his flight deck Luddites. In addition to paper, printer and two EFBs, the crews carry an extra computer and a CD of the Jeppesen data for backup. "I'm 99.9-percent electronic," he says. Geraci says ADR provides cigarette lighter adapters with all units, though many operators opt for making a permanent electrical hookup, a choice that runs about $800 for parts plus installation costs.

Taking the next step up – mounting Class II EFBs in the cockpit either via yokemount or swing-arm- requires FAA approval, an inconsistent process and represents a quantum jump in cost and much more cumbersome path. It took Gulfstream two years to obtain an STC to incorporate CT-lOOOG EFBs, built by CMC Electronics (previously Northstar), on the yoke of the GIV and GIV-SP (see B/CA, March 2002, page 50) as a Class II application, though the EFB classifications had not been finalized at the time.

Jean-Marie Begis, director of aeronautical communications for Quebec-based CMC, says there are more than 200 CT- 1000G units in the field, both with yoke and side mounts, and about seven shops are doing retrofit STCs, costing roughly $50,000 to $75,000 for a dual installation. The EFBs have a 6.4-inch (diagonal) screen and run JeppView FliteDeck and other applications, including weight and balance and preflight planning, on a Pentium processor running Windows 98. The EFBs are standard equipment on new GIVs and GIV-SPs. As for how long it takes to retrofit an older aircraft, Begis says the work usually fits in well with other regularly scheduled maintenance. From his vantage point, Begis says, installing EFBs in many cases has become a "stop gap" measure for owners without advanced avionics.

A new entrant into the Class II market this fall is ARINC, with its eFlightDeck system based on the Panasonic Toughbook CF-18 computer, "Flight-man" software programs by Dublin, Ireland-based Aircraft Management Technologies and ARINC's customized applications and established communications network. Designed around the needs of DHL for its Boeing 727 fleet, the system will have an open hardware architecture allowing connection to any EFB and existing Ethernet lines in the aircraft, says Rolf Stefani, director of business development at ARINC. When available, Stefani says, a dual system with docking station built by Gamber-Johnson and all options for a business jet will cost under $50,000 per aircraft. Options will include the usual Class II menu items - Jepp charts, aircraft and operation documentation, weight and balance, graphic weather and cabin video - but also a host of features generally found only in Class III programs such as the ability to monitor aircraft doors and automatically send a cell phone call out if someone disturbs the aircraft on the ground anywhere in the world.

The market potential for Class III systems for business jets appears to be healthy as companies like Teledyne Controls, Rockwell Collins and others have decided to hunch new products in a field dominated by companies like Astronautics and Universal Avionics. However, with the first units just now going operational, there's little feedback on what pilots think about Class IIIs.

Teledyne Controls, which recently bought Spirent Systems, is considering making a business jet version of its multi-purpose aircraft computer (MPAC) Class III EFB system, flying as a one-piece unit on Qantas Airbus A330s and soon as a two piece "tethered" (display separate from computer) unit on a Continental Airlines Boeing 777. Target price for the system will be $20,000 per side and will include Spirent's aircraft performance software applications used by Southwest Airlines, JetBlue and Atlas Air in addition to fault reporting programs used by FedEx.

Rockwell Collins' new EFB for the Pro Line 21 avionics suite was certified in September in the company Challenger 601. Called the Integrated Flight Information System (IFIS), the enhancement is a retrofit for the Pro Line 21 avionics package and includes Jeppesen electronic charts, enhanced map overlays for the 10.4-inch multifunction display that include geopolitical features, airspace and airways. The system gets graphical weather through XM and NEXRAD, and winds, temperature, icing.

Astronautics, whose Class III EFB is fly-in on several air carrier B777s and a private B767, is hoping to break into the bus i-ness jet and regional market through a proposal to retrofit three SwissAir Ambulance Challenger 6O4s with its EFBs. Like the air carrier design, the Challenger EFB would feature two side-mounted 6-by-8-inch touchscreen active matrix liquid displays tethered to computers located elsewhere. The company is also developing a Class II system that would be upward compatible to a Class III.

Universal Avionics has STCs in place for a two-piece Class III EFB called the Universal Cockpit Display (UCD) on the BBJ, Challenger 601, Global Express, Falcon 50, King Air 350and others. Don Berlin, vice president and marketing manager for Universal, says a dual system is priced at $32,000, uninstalled, include-in two 8.4-inch touchscreen displays with cable connection to the computer system. New features recently announced include an electronic documents system and uplink text and graphical weather services through the company's UniLink 701 data link. Berlin says OEMs working on STCs for the UCD include Dassault for the Falcon 2000 and Gulfstream for the G500, Cessna for the Citation Bravo and Bombardier for its Learjet line. "Once we get it into the Citations and Learjets, I think the fractionals will jump on it," says Berlin.

B/CA

Certification Confusion: Form337 or an STC

Both the FAA and industry realize there's a lot work yet to do when it comes to regulating or controlling the use of EFBs in the cockpit. Major issues confronting working groups include the process for installing and using various types of systems and the rules for displaying "own-ship" position - the symbol or "spotter" that shows the location of your aircraft on the approach, plate or airport chart.

While it's clear that Class III EFBs, those that are permanently mounted and have a two-way data connection to the FMS or other flight critical systems, require an STC or TC along with nods from FAA certification and flight standards groups, there's much more wiggle room when it comes to Class II hardware, the portable devices most often used to replace paper charts in the cockpit.

Rick Brainard, director of avionics sales for Texas-based McKinney Aerospace, says the cost and difficulty of Class II installations varies depending on which FSDO you work through. In some cases, operators are able to install yoke and swing arm mounts via Form 337, but in other cases, the FAA inspector wants an STC for what is essentially the same installation.

" That's probably the biggest area of confusion: Field approval (Form 337) versus STC is different for everyone who goes through it;” says Brainard. "A lot of flight departments are doing nothing because they've heard the horror stories of people going through the process."

Other EFB vendors and FAR Part 135 users tell B/CA that the amount of effort required to obtain a letter of authorization to use the electronic chart capabilities varies by FSDO as well.

The FAA is aware of the confusion, and along with the Air Transport Association (ATA) and others, is in the process of collecting comments from the field. "We're very much at the front end of this,” says John McGraw, manager of the FAA’s flight technologies and procedures division, "We're trying to minimize the level of FAA involvement depending on the criticality of function.” Differences of opinion regarding criticality of function are nowhere more prevalent than with own-ship position. The way the Advisory Circular (AC) is written today, operators wishing to overlay the aircraft's FMS-generated position on charts must go through the rigorous and costly Class III STC or TC approval process that involves heavy interaction with FAA certification and flight standards people. Most, if not all, overlays are generated with JeppView FliteDeck electronic chart software, which is setup to show aircraft position overlays at speeds up to 60 knots, enough to give operators what they're really after - situational awareness particularly at unfamiliar airports in bad weather and at night. Gulfstream's STC for its Class II CMC CT-1000G EFB is an exception to the rules as the STC was approved before the latest AC was published.

Pilots, however, are questioning whether safety could be improved by allowing own-ship displays on lower-cost non-certified Class II EFBs - equipment like the FG-3600. ''If I put a little airplane on it, there's a faction that says the compelling nature will cause someone to navigate with it, so it's required to be a Class III system" says Brian Uskoski, chairman of the ATA's digital display working group. "There's another faction that says that's ridiculous.”

The FAA appears to be keeping an open mind on the issue and is right now finalizing a TSO that will allow Class II EFB providers to display own-ship position on their units. McGraw says the TSO will "cut the bureaucracy" for approvals, requiring a higher level of software assurance but not the overhead and extra expense of an STC.

In the real world, B/CA found that some pilots regularly use the serial port capability of units like the FG-3600 to feed in a GPS signal that is then used for own-ship position, eliminating the connection to an FMS. The FAA fears such cobbled systems could possibly produce misleading information, creating hazardous situations.

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