eprn1n2

I fly full time Part 121 but on occasion I do Part 91 ferry work. I'm not familiar with the chart requirements for 91. Can a Garmin with a chart reader be used or are paper charts required?

twebb

http://www.airweb.faa.gov/Regulatory...AC%2091_78.pdf

Looks like it depends on the model.

minitour

With the exception of large and turbine powered multi-engine airplanes (91.500s), under part 91 you aren't required to have any charts on board. You just have to have the information you need to safely complete the flight.

-mini

2StgTurbine

That vague requirement in the hands of the FAA pretty much means if the stuff hits the fan and the electronic charts you have are not working and you have no paper charts on board, you could be violated for not having all the information you need to safely complete the flight.

Personally, I feel comfortable without paper charts on board. Paper charts are just as likely to fail as electronic ones. I had a door seal break in flight and the rain water dripped on my charts making most of them difficult to read.

minitour

Source?

I could ask ATC for every procedure if I wanted to. All I need for a SIAP is a text description. NOS and Jepp are just nice enough to make the text plan into little pictures for me to follow.

All I need to "safely" complete a flight that is going to terminate with an ILS (Vectors to final) is the LOC frequency, the inbound course, the altitude at the OM, the DA, and the missed approach instructions.

I don't need to know (to complete the flight safely) what lighting to look for, what the tower frequency is, what the name of the airport is, when the chart was revised, what amendment number it is, when it was printed, or whether the Airline terminal ramp is a non-movement area. All I need to know is how to get to the bottom of the approach, where the bottom is, and what to do if I get to the bottom and don't see what I need to see.

That is especially true when it's forecast to be 1000-3 or better.

-mini

FlyerJosh

No source, but if you start asking ATC for approach procedures all the time, it's going to raise some flags.

Even though the reg doesn't specifically cover it, if you end up screwing up along the way, the FAA could hang you on 91.103:

§ 91.103 Preflight action.
Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

That's how they ended up jumping on this guy:
NATCA | Media Center

2StgTurbine

The source is 91.103. "All information concerning the flight" is subjective. My point was not to say that you must have paper charts. I was trying to show that when it comes to regulations, the FAA can interpret them in any way they desire that is not necessarily “legal”. These are regulations, not laws.

You are right, you only need the description for the approach, but if you only have electronic charts and they fail, then you have nothing else. I was saying you should always have a backup to avoid any trouble from a power hungry FAA inspector.

minitour

Our POI has approved our EFB program for certain aircraft. The backup for that program is to 1) Use the sat phone to get charts faxed to us from dispatch (which we can't do - no fax - no sat phone), 2) query Air Traffic Control for approach information.

Accepted by the POI. Op Spec issued for EFB paperless cockpit usage.

Good enough for the FAA for 135. Good enough for 91.

If we have the EFBs go T.U. during a flight, we just ask for the procedure information. Prior to the next flight, if the units are still T.U., we need to have paper on board, but that's because 135 specifically says you need to have charts on board. Nothing under part 91 does that...outside of the 91.500s.

-mini

2StgTurbine

That is the nice thing about 135. You get your procedures approved by the FAA beforehand. The FAA has already agreed that for your specific operation, that you do not need paper backups.

For part 91, you are in uncharted waters. There are no actual regulations regarding EFBs with 91. Just because some 135 and 121 operators are approved does not mean that any part 91 aircraft is approved. If a C-172 causes a backup at a major airport because their EFB failed and the media latched on to the story, the FAA will be all over you. If you were operating under part 135, you just have to show them your Op Spec. Part 91, you are relaying on them to interpret the FARs the same way you did.

There is nothing saying you need paper backups, but there have been no official FAA rulings or interpretations when it comes to EFBs and part 91. If you feel comfortable testing the FAAs interpretations with your certificate go ahead.

And also, the op is talking about ferrying aircraft. There are so any unknowns when you ferry aircraft and lots of things tend to get rushed. The last G1000 I did had a chart subscription, and it ran out the day after the flight. If the ferry got delayed one day, then we would have been stuck at an airport waiting the pilot shop to open before we could go.

minitour

That's because, if you read the AC regarding EFBs, it specifies that no approval process is necessary for Part 91. Not that you can't use them. No approval process is necessary.

Bottom line is this...

1) Air carrier regulations specifically state that a current chart (in some form) has to be on board and used.
2) Part 91 regulations (outside of large and turbine powered multiengine aircraft and 91k) do not specifically state that a current chart in some form must be on board and used.
3) The advisory circular published for EFB approval specifically (there's that word again) states that Part 91 requires no approval (for an EFB that's just going to be a chart reader. If you want it to communicate with aircraft systems and/or connect to the aircraft, you may need a 337 or field approval or even an STC, but that's a different discussion).
4) If you want a worldwide Jepp subscription to take a 172 from ORL to DAB......I'm sure Jepp will be happy to send you a care package every two weeks.

To me (and anyone else I know using EFBs under part 91) an EFB is an acceptable means for using charts and a great way to dump 80# of Jepp binders and hours of revisions! If it fails, I'll ask for a read-out of the chart data. If the FAA wants to revoke my certificate for it (after several air carriers use that very same method), then I guess it's time to take up under water basket weaving. My guess is this...

Since the FAA has said that an air carrier (who have much more over-sight than Ma' N' Pa' Kettle in their King Air 90 or Seneca or Citation or 206 or...) can use the EFB with a backup plan to simply ask for the procedure data, I really don't think they're going to come after you for that every once in a while (and mine has never failed...I've never out-flown the battery life...I've never had charts not current on it) when the EFB for some reason fails and you ask for the info on ATC.

I'd love to see a case where they did violate someone for flying with an EFB and no paper...and the EFB failed...and they asked for a readout of the chart data. Anyone? I'm just not motivated enough to sit on the FAA's website tonight searching for legal counsel opinions. But I digest ()...

Hell, just a few months ago we were inbound to an airport and Jeppesen didn't send us the chart we needed. It just wasn't in the binder. We even checked different airports to see if it had been re-filed incorrectly. My personal EFB was in the back, since we hadn't gotten approval yet and I was using it only on the 91 legs. So what was I to do? I asked approach for the important information, landed, called Jepp, we got the chart 4 days later, the world kept on turning. No delays were caused. Yes, it was a larger airport in the NY area. If your EFB fails and you ask for the procedure, they aren't going to stick you in a hold or clear traffic for you. They'll get you the info you need and get you on the ground so you don't become a problem.

....I'm still waiting on my enforcement action.

Anyway, if there's a paranoia about not having paper charts on board, then the easiest solutions is.........get a paper subscription. There's no benefit to have an EFB or electronic chart subscription and then have the paper on board anyway. You're doubling your expense, not losing any of the weight, still doing the revisions and adding complexity to your operations ("do we use paper today or the e-charts?" - "should we have the paper out but use the e-chart as the primary chart?"). Simple solution, just use the paper.

I've thought about dumping my EFB in favor of having paper again (for billing purposes) but I just can't bring myself to sit down and do revisions again.......and I'm too cheap for, and don't like Q service. And since the feds don't say I have to have anything on board (and the EFB is better than that already), I'm good to go.

It takes Diff'rent strokes to rule the world!

-mini