Replacing paper – Sources of aeronautical information and primary means of navigation: what are the rules?

The OzRunways team gets asked frequently about the rules regarding EFB usage; is it legal? Do I need a paper backup? We get asked these questions a lot and it leads us to believe that there is some degree of confusion amongst pilots and local authorities, with some people relying on out-dated or inaccurate information. So in this post, we are not only going to explain the rules around EFB usage, but we are going to provide you with the exact references for where to confirm them for yourself. Now to be upfront, this subject has the potential to be like eating weetbix with no milk, but we will do our best to keep it interesting!

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The line-up at old station, 2016 – as always plenty of OzRunways subscribers on hand. Big shout out to the Buccaneers!

So why this post? Well, aside from the questions we get on this topic, we need to get this information out there because we have read, seen and heard various people (including a few wayward individuals from within the regulator) spreading misleading information about the legality of EFB usage. We also come across people every now and again who try to dissuade other pilots from using EFBs for various ill-founded or misunderstood reasons – it is usually not their fault as it can be tough to pin down the rules on new technology like EFB’s and in the absence of definitive guidance people tend to want to keep things the way they have always been done. Lets briefly put to bed one of the major reasons some are on the wrong side of history with respect to EFB’s, that is their potential limitations.

Like pretty much everything in aviation, EFB’s have limitations which if poorly understood and left untreated, can cause safety issues. But paper is not vastly different in this regard, it is just that people are used to paper’s limitations thus give them little thought day to day. For those who, like the OzRunways team did, grew up flying with ‘paper’ products, ask yourself; Ever had a paper map fly out a vent or open window, or blown in to the back seat out of reach? Ever had an air-conditioning vent spew ice and water on to your map, rendering it a soggy, unreadable mess? Ever gone to fold a map only to have it split as a result of being folded one too many times? Ever inadvertently flown with an out of date map, ERSA or approach plate? Ever opened your flight bag only to realise the one map or chart you need isn’t in there at a crucial time? I have had every single one of these things happen to me at least once in my career and many of you would have had the same. This small list of problems is exclusive to paper products and pilots had for years accepted these limitations and worked around them, probably without even realising; keeping maps deliberately away from vents, pointing A/C outlets in safe directions, taking care when folding maps, having a disciplined pre-flight NAV bag check are all steps pilots would take without giving it too much thought – it is the way we have always done it.

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The pilots of these beautiful antiques certainly appreciate not having paper maps. Echuca 2016.

The good news is that managing the limitations of EFB’s is no harder, but it does require a different way of thinking. Overheating, battery limitations, lack of impact resistance, data updates, these things are all limitations exclusive to EFB’s which can be just as easily overcome through good practice and developing sound procedures, just like pilots have done with paper since the the dawn of aviation. The modern pilot can easily set themselves up for success through having having a heat resistant tablet cover, carrying spare batteries or have charging in the aircraft, smart ‘screen’ toggling, impact resistant covers, deliberate EFB pre-flighting – none of these mitigating actions is significantly more burdensome than what the pilots of yesteryear had to deal with, they are just different.

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Maps can deteriorate quickly making them hard to read, especially in low light conditions.

So with that out of the way, what exactly are the rules for using an EFB? Let us explain it to you using the type of questions we typically get on this subject.

I am flying privately under the IFR/VFR. Can I use an EFB as the sole source of my maps and charts? Yes! For private operations, an approved EFB may be relied upon as the sole source of aeronautical information to a pilot in flight. (Ref CAR 233, CASR part 175, Electronic Transactions Act 199)

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What is an approved EFB? An ‘approved EFB’ is technically a type of ‘approved service’ which can be used by Data Service Provider (DSP) to transmit aeronautical information. Importantly, a DSP must have been approved by CASA and issued a CASR Part 175.295 certificate, such as OzRunways was in March of 2016. An Aeronautical Information Service (AIS) could also technically produce an EFB. There is only one AIS in Australia however, Airservices Australia, and they don’t produce an EFB. The list of DSP’s can be found here. (Ref CASR Part 175)

Do I need a backup if I use an EFB? Legally, there is no requirement mandating the carriage of a backup for private operations. However, it is so easy to have one and good airmanship suggests it is a great idea, so why wouldn’t you? OzRunways recommends that for VFR flights outside of your local area that you carry an appropriate backup (see later paragraphs for more information). If you are privately flying IFR in IMC, OzRunways recommends carrying a second tablet, as shooting an approach off a chart on a phone whilst not impossible, is difficult.

If I carry a backup, does it need to be paper or can I use another tablet/phone? What is appropriate? There is no requirement to use paper charts as a backup to an EFB. Another EFB (either on a tablet or phone) is more than appropriate as a backup. This is reason your subscription with us automatically gives you access to the app on one tablet and one phone, so you have a backup (which you can mix and match between iOS and Android as desired). It is also the reason why we designed the OzRunways Premium with the personal backup tablet licence – so you can have two tablets without needing another subscription. If you want to fly VFR with a backup tablet, the personal back is available as a stand alone add on as well – it duplicates your active subs to a second device. Remember though, if you use another device running OzRunways/RWY as a backup, make sure it is charged and up-to-date before you go flying, just as you do with your primary EFB.

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Luckily iPad failures are very rare, but why not carry a backup? The iPhone is a great backup especially for VFR flying, but flying an approach from one in IMC conditions can be challenging depending on your cockpit setup – OzRunways recommends a second iPad for IFR flying where possible – the OzRunways Premium subscription is great value with all the Australian data plus a personal backup license which enables your subscription on two tablets and one phone.

Isn’t a phone too small to use as an EFB? Is there a lower size limit for an EFB? There is no legal minimum size but CASA state that greater than 200mm diagonal for screen size is recommended. The iPad mini meets this minimum suggested screen size. A phone is typically smaller than 200mm diagonally, but for private operations it can be used as a backup; it will do the job in the unlikely event you needed it – just beware a phone is much harder to use, especially in turbulence/IMC. OzRunways doesn’t recommend using a phone as a primary EFB device.

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No matter the mission, OzRunways is as a safe bet – thats why it is trusted by our defence force (and the RNZAF). OzRunways is the EFB used by every Air Mobility Group platform, such as the mighty C-130, and the RAN Fleet Air Arm.

Can I get in trouble at a Ramp Check with CASA if I rely solely on OzRunways? No. It is not only legal, it is safe to rely on OzRunways as your sole source of aeronautical information. If you get ramp checked you must be able to demonstrate that your OzRunways installation complies with the requirements of CAR 233, which includes having the required maps and charts downloaded to the device (On demand downloads do not satisfy this requirement), plus sufficient charge on your device to conduct your intended flight. The introduction of the Electronic Transactions Act 1999 means that electronic documents are every bit as valid and legal as paper documents – hence why information on a tablet, from an approved source is legal. AOC holders must comply with their AOC.

Can I keep my flight log in OzRunways? Do I need to keep a paper flight log? You can keep your flight log in OzRunways. There is no need to keep a paper flight log, unless you want to.To quote CASA on the subject (From CAAP 233):

‘The Acts Interpretation Act 1901; and the Electronic Transactions Act 1999 are the enabling legislation allowing the use of digital media to display the documentation required by the Civil Aviation Act 1988 and any of its subordinate regulations’
 
It is quite clear – you can keep a log digitally and you can’t be sanctioned at a ramp check for using your iPad to log your times and fuels. CASA staff familiar with the law will be able to confirm this for you.

Reg’s are a pain, what is this CAR 233, what does it say and how do I find it? You can find this CAR here or in the OzRunways App (OzRunways>Documents>CAR 1988 Volume 3>page 130). This CAR states a pilot must ensure that before commencing a flight that any aeronautical data and information required is carried in the aircraft and readily accessible to the flight crew. (Ref CAR 233)

What aeronautical information and data is required for a flight? The aeronautical data and information you require is that which is applicable to the route to be flown and to any alternative route that may be flown, and this data must be published by a Data Service Provider (CASR Part 175.295 certificate holder, such as OzRunways) or AirServices Australia. Think along the lines of maps, approach plates, ERSA, RDS etc. You can always discuss with a local flying instructor if you aren’t 100% sure. (Ref CAR 233, CASR Part 175)

I still feel more comfortable flying paper maps and charts though…maybe just as a backup Before we answer, let us start by saying the unique thing about the OzRunways team is that we are not just nerds, we are all qualified pilots –we have extensive experience in aviation among our team, including flying instructors with experience in RAAus, aerobatics, military, GA, Multi-engine heavy and jet experience. Add to that two of our people are human factors and aviation safety experts. OzRunways aren’t just the experts on EFB’s, we know flying safety as well. When it comes to someone still wanting to use paper, our answer is this: If you are not yet comfortable jumping straight from paper to EFB, then you should carry paper with you as well until you are happy to go all electronic. Or if you prefer a paper back-up, then use paper as a backup until such time as you feel it isn’t necessary. OzRunways is not ‘EFB at all costs’ – we are more passionate about airmanship and flying safely than EFB’s. But we know that even those who prefer paper will eventually see the benefits of having an EFB. If you think paper is needed in your cockpit to keep you safe while you transition to the OzRunways EFB, then there is no doubt in our minds, nor should there be in yours that you should use paper until the time comes you feel you can move away from it.

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Still need paper? Why not print from OzRunways! Maps printed from OzRunways are safe and legal to use in flight. With iOS 10 you can also print to pdf from within the app.

Getting Started. We would certainly recommend that before you fly with OzRunways EFB for the first time you spend time with it on the ground getting used to it – check out some of video’s here, ask people in your local flying network for tips on how to set it up to suit your way of doing business. Also, it can help if you take some lessons with an instructor to get used to using an EFB (unfortunately CASA don’t yet have EFB’s in the pilot training syllabus). Long term the situational awareness benefits, ease of manipulation and immense data capacity of an EFB means it far outweighs using paper for aeronautical information.

If you do wish to use paper for any reason, remember: you can print from OzRunways! Save some tress and print what you need from the app – it is way more convenient and cheaper than sending off for AirServices charts. Printed material from OzRunways is still legal as it is from a DSP approved service.

I am an AOC holder, can I use OzRunways EFB? Yes, but CASA needs to approve this through your operations manual. See the CASA website for more information, including CAAP 233-1 (this CAAP is getting long in the tooth now and hasn’t been updated since CASR Part 175, but still has some useful information).

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Would you rather carry an iPad or a 9kg NAV bag with most of the AIP – EFB’s can carry a substantial amount of data which is a benefit to private operators and AOC holders alike.

I am an AOC holder and I want to use EFBs but it seems like a lot of hassle Well the good news is OzRunways can help! We have the experience in house to help develop procedures and amend your AOC. Get in touch with us through OzRunways Support (help.ozrunways.com) to find out more.

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You know whats more hassle than amending an Ops Manual? DAP amendments! Moving to a paperless flight deck is worth the investment. OzRunways intelligent design makes it so versatile, it suits everyone from the weekend trike flyer through to the IFR heavy flight deck.

Lastly, lets talk about ‘primary means of navigation’ and the OzRunways EFB. This phrase gets misinterpreted a lot, which is understandable given the phraseology can mislead pilots in to thinking that you can’t use OzRunways to gain navigation information. The question we often get goes something like:

But I heard we can’t use OzRunways as the primary means of navigation, how can it be legal? The restriction of use for primary means of navigation is referring to specific navigation elements of the EFB: in particular, any device derived GPS position data such as  your OzRunways aircraft position, present lat/long, HSI display etc. These features of the app can only be used as a supplement to your primary navigation source. They are there to enhance your situational awareness only – that is, treat the iPad position data as a ‘VFR GPS’.

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OzRunways is used by the ADFs aviation training units, including ADF Basic Flying Training School in Tamworth, NSW.

As an example, you can’t fix yourself by looking at the OzRunways EFB, seeing the aeroplane symbol over a town and saying ‘the OzRunways aircraft symbol says I am here therefor I have fixed my position’ – that would be relying on the device GPS as a primary means of navigation which you cannot do. What you can do though is look at the EFB, see the aeroplane symbol over a town, assess the other features on the map around the town OzRunways says you are over, then look outside and do a Clock to Map to Ground visual pinpoint to fix yourself. Of course it is more than likely that your visual pinpoint will correlate with your iPad GPS position shown in the EFB. This is called using the OzRunways EFB as a supplemental source for navigational information – it is there to assist you in position fixing and provide enhanced ‘situational awareness’ which can supplement your primary means of navigation.

When using OzRunways, you must position fix using either a proper visual fix or approved NAVAID in accordance with the section of AIP relevant to your category of flight (such as a VOR/NDB if you can find one, or a CERTIFIED GPS fitted to your aircraft – remember certified equipment and certified pilot are needed here – see AIP for more information). Again though, don’t be confused – you can use the OzRunways EFB to derive the aeronautical information needed to assist you to fix yourself though (i.e. the maps are legal to use to discern features, frequencies etc).

One thing it is worth reminding pilots of – the restriction on using OzRunways as the means of primary navigation also means your OzRunways GPS position isn’t a valid way of avoiding airspace (restricted or controlled) – you MUST avoid airspace using an approved means of navigation (and by the appropriate margin!).

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So to sum it all up – The Aeronautical information in OzRunways EFB is legal; it is good to go as a sole source for private operations (AOC holders must comply with the requirements of their OPS manual); OzRunways EFB GPS position information is only to be used to supplement your primary means of navigation.

Thanks for sticking with it if you got this far! Fly safe, see you at your next local air-show or fly-in.

 

The OzRunways team

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